ABT Galveston Limited Partnership ("ABT") and the CIT Group/Equipment Financing, Inc., ("CIT") v. Galveston Central Appraisal District

CourtCourt of Appeals of Texas
DecidedMarch 30, 2004
Docket01-01-00956-CV
StatusPublished

This text of ABT Galveston Limited Partnership ("ABT") and the CIT Group/Equipment Financing, Inc., ("CIT") v. Galveston Central Appraisal District (ABT Galveston Limited Partnership ("ABT") and the CIT Group/Equipment Financing, Inc., ("CIT") v. Galveston Central Appraisal District) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ABT Galveston Limited Partnership ("ABT") and the CIT Group/Equipment Financing, Inc., ("CIT") v. Galveston Central Appraisal District, (Tex. Ct. App. 2004).

Opinion

Opinion issued March 30, 2004






In The

Court of Appeals

For The

First District of Texas


NO. 01-01-00956-CV

____________

ABT GALVESTON LIMITED PARTNERSHIP AND

THE CIT GROUP/EQUIPMENT FINANCING, INC.,

Appellants


V.


GALVESTON CENTRAL APPRAISAL DISTRICT,

CITY OF GALVESTON, GALVESTON COUNTY,

GALVESTON COMMUNITY COLLEGE DISTRICT,

GALVESTON INDEPENDENT SCHOOL DISTRICT, AND

GALVESTON COUNTY NAVIGATION DISTRICT NO. 1, Appellees


On Appeal from the 212th District Court

Galveston County, Texas

Trial Court Cause No. 98CV0898



O P I N I O N


          Appellants, ABT Galveston Limited Partnership (ABT) and The CIT Group/Equipment Financing, Inc. (CIT), challenge the trial court’s rendition of summary judgment against them on their claims regarding the cancellation of ad valorem property tax exemptions, the “unlawful assessment and collection of property taxes,” and interest due on overpaid ad valorem property taxes brought against appellee, the Galveston Central Appraisal District (GCAD), and appellees, the City of Galveston (the City), Galveston County (the County), the Galveston Community College District (GCCD), the Galveston Independent School District (GISD), and Galveston County Navigation District No. 1 (the Navigation District) (collectively, the taxing authorities).

          In two issues, ABT and CIT contend that the trial court erred in granting (1) GCAD’s motion for summary judgment and (2) the taxing authorities, motion for summary judgment. We affirm.

Facts and Procedural Background

          In 1994, ABT, a lessee of certain tracts of property located at the Port of Galveston and owned by the City of Galveston Wharves Board, and the taxing authorities executed separate ad valorem property tax abatement agreements in anticipation of ABT’s construction of an automated grain bagging and loading facility at the Port. The agreements provided that, in exchange for completing the proposed construction and capital improvements, estimated at $23 million, ABT would receive, for a period of seven years after completing construction, tax exemptions on the full amount of the increases in value to the certified appraised value of the property resulting from the improvements.

          Each of the abatement agreements provided that the pertinent taxing authority could declare its agreement in default if ABT did not comply with its obligations, including its obligations to (1) make the agreed upon improvements and (2) pay timely any ad valorem taxes owed on the property. Each agreement required the taxing authorities to give ABT written notice of, and 60 days to cure, any alleged default before cancelling the exemption. ABT’s agreements with the City, GISD, GCCD, and the Navigation District also included a “recapture” clause, which read as follows:

In the event that the facility is completed and begins producing products or services, but thereafter discontinues producing products or services for any reason excepting fire, explosion or other casualty or accident or natural disaster for a period of one (1) year during the abatement, then this Agreement shall terminate and so shall the abatement of the taxes for the calendar year during which the facility no longer produces. The taxes otherwise abated for that calendar year shall be paid to the affected jurisdiction within sixty (60) days from the date of termination.

          ABT obtained financing for the project from CIT and, in early 1996, completed the construction of the facility and began operations. In April 1996, ABT filed its application for a property tax exemption, pursuant to the terms of the abatement agreements. GCAD retained Capitol Appraisal Group, Inc. to appraise the value of the facility. On June 16, 1996, Michael Durham, who was ABT’s financial planner and had previously been employed as a Deputy Chief Appraiser for GCAD, received a fax from Capitol Appraisal Group (CAG), informing him that CAG had determined that the market value of the facility was $21,670,900. GCAD’s certified appraisal roll reflected this value as of July 1996.

          ABT’s business was financially unsuccessful and, by the end of June 1996, ABT had stopped repayment of its loan obligations to CIT and had ceased operations at the facility. In September 1996, CIT decided to foreclose on the assets at the facility and to locate an outside party to purchase them. CIT subsequently began negotiations to sell the facility’s movable assets to the Port of Lake Charles, Louisiana. By letter dated October 17, 1996, Timothy Bennett, a CIT vice president, solicited an offer from the Port of Lake Charles to purchase the facility’s movable assets for $15.5 million. According to Bennett’s deposition testimony, the Port of Lake Charles agreed to purchase the facility’s assets for $14,375,000 within “a matter of weeks.”

          At a meeting held at the end of October 1996, representatives of the taxing authorities informed representatives of ABT and CIT that, if any assets of the facility were sold with the intent to move them out of Galveston County, a tax lien would be applied to those assets and the assets would not be permitted to leave the property without satisfaction of the lien. Following this meeting, GISD, the Navigation District, and the City all notified ABT—by letters dated October 25, November 1, and November 22, 1996, respectively—that ABT was in default of the abatement agreements.

          At all relevant times, Mary Ellen Reinarz, with Galveston Tax Collections, served as the tax assessor for GISD, the City, the Navigation District, and GCCD. On December 6, 1996, Reinarz sent CIT a consolidated tax bill indicating that the 1996 appraised value of the facility was $21,671,900 and demanding $491,780.93 as the amount of the 1996 property taxes due to GISD, the City, the Navigation District, and GCCD by January 31, 1997. Also in December 1996, the governing bodies of those four taxing authorities voted to cancel the tax abatement agreements with ABT.

          On December 20, 1996, the County also notified ABT that it was in default of its tax abatement agreement with the County.

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ABT Galveston Limited Partnership ("ABT") and the CIT Group/Equipment Financing, Inc., ("CIT") v. Galveston Central Appraisal District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/abt-galveston-limited-partnership-abt-and-the-cit--texapp-2004.