Strayhorn v. Willow Creek Resources, Inc.

OPINION

BEA ANN SMITH, Justice.

In this case, we determine whether the informal review of a tax-refund claim pro vided by tax code section 111.1042 tolls the statute of limitations for filing that claim. See Tex. Tax Code Ann. § 111.1042 (West Supp.2004-05). To do this, we must construe the term “administrative proceeding,” as it was used in tax code section 111.207(d), 1 to ascertain whether the legislature intended to include the informal review of a tax-refund claim. Appellant, the Comptroller, contends that the legislature intended the term “administrative proceeding” in former section…