Harris County Appraisal District and Harris County Appraisal Review Board v. Primrose Houston 7 Housing, L.P.

CourtCourt of Appeals of Texas
DecidedAugust 16, 2007
Docket01-06-00691-CV
StatusPublished

This text of Harris County Appraisal District and Harris County Appraisal Review Board v. Primrose Houston 7 Housing, L.P. (Harris County Appraisal District and Harris County Appraisal Review Board v. Primrose Houston 7 Housing, L.P.) 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
Harris County Appraisal District and Harris County Appraisal Review Board v. Primrose Houston 7 Housing, L.P., (Tex. Ct. App. 2007).

Opinion

Opinion issued August 16, 2007





In The

Court of Appeals

For The

First District of Texas



NO. 01-06-00691-CV

____________



HARRIS COUNTY APPRAISAL DISTRICT AND HARRIS COUNTY APPRAISAL REVIEW BOARD, Appellants



V.



PRIMROSE HOUSTON 7 HOUSING, L.P., Appellee



On Appeal from the 11th District Court

Harris County, Texas

Trial Court Cause No. 2005-03139



O P I N I O N

Appellants, Harris County Appraisal District and Harris County Appraisal Review Board (collectively "HCAD"), challenge the trial court's summary judgment in favor of appellee, Primrose Houston 7 Housing, L.P. ("Primrose L.P."), on Primrose L.P.'s claim that it is entitled to an exemption from 2003 ad valorem taxes it sought under section 11.182 of the Texas Tax Code. (1) In two issues, HCAD contends that the trial court erred in denying HCAD's motion for summary judgment and in granting Primrose L.P.'s motion for summary judgment because Primrose L.P. is not entitled to the property tax exemption authorized by article VIII, section 2(a) of the Texas Constitution (2) and the enabling legislation, sections 11.18 and 11.182 of the Texas Tax Code. (3)

We reverse and render judgment in favor of HCAD.

Factual and Procedural Background

Primrose L.P., a for-profit limited partnership, is the owner of the 280-unit Primrose Casa Bella apartment complex ("the apartments") located at 5000-5100 Airline Drive in Houston, Texas. Construction of the apartments was in large part publicly financed with low-income housing tax credits, tax-exempt bonds, and a loan from the City of Houston. Primrose L.P. is structured with Primrose Houston 7 Development L.L.C. ("Primrose L.L.C.") as its general partner with a 0.01% interest, (4) MMA Special Limited Partner, Inc. ("MMA Special") as a special limited partner with a 0.00% interest, (5) MMA Financial Warehousing, L.L.C. ("MMA Financial") as an investor limited partner with a 99.99% interest, (6) and Primrose Skyline Apartments SLP, L.L.C. ("Primrose SLP") as a class B limited partner with a 0.00% interest. (7)

On December 19, 2003, Brian Potashnik assigned his 100% interest in the general partner, Primrose L.L.C., to Southeast Texas Housing Partners, Inc. ("Southeast Partners"). Southeast Partners is organized as a non-profit corporation and is recognized as a community housing development organization ("CHDO"). (8)

This dispute arose when, on January 2, 2004, HCAD received from Southeast Partners an "Application for Community Housing Development Organization Improving Property for Low-Income and Moderate-Income Housing Property Tax Exemption" seeking an ad valorem tax exemption for the apartments for 2003 and all subsequent years. Southeast Partners filed the application on behalf of Primrose L.P. After HCAD denied the application on the ground that Primrose L.P. did not meet the exemption requirements, Primrose L.P. filed suit in the district court. Both parties filed motions for summary judgment, and the trial court denied HCAD's motion and entered judgment that Primrose L.P. is entitled to the tax exemption.Standard of Review

A party moving for summary judgment has the burden of proving that there is no genuine issue of material fact and that it is entitled to judgment as a matter of law. Tex. R. Civ. P. 166a(c); Nixon v. Mr. Prop. Mgmt. Co., Inc., 690 S.W.2d 546, 548 (Tex. 1985); Farah v. Mafrige & Kormanik, P.C., 927 S.W.2d 663, 670 (Tex. App.--Houston [1st Dist.] 1996, no writ). When reviewing a summary judgment, we take as true all evidence favorable to the nonmovant, and we indulge every reasonable inference and resolve any doubts in the nonmovant's favor. Valence Operating Co. v. Dorsett, 164 S.W.3d 656, 661 (Tex. 2005). When both parties move for summary judgment on the same issue and the trial court grants one motion and denies the other, as here, we consider the summary judgment evidence presented by both sides, determine all questions presented, and, if we determine that the trial court erred, render the judgment that the trial court should have rendered. Id.

Property Tax Exemption

In two issues, HCAD argues that the trial court erred in denying its summary judgment motion and in granting Primrose L.P.'s summary judgment motion because Primrose L.P. is not entitled to the property tax exemption authorized by article VIII, section 2(a) of the Texas Constitution (9) and the enabling legislation, sections 11.18 and 11.182 of the Texas Tax Code. See Tex. Const. art. VIII, § 2(a); Tex. Tax Code Ann. §§ 11.18, 11.182 (Vernon Supp. 2006).

Section 11.182 allows an organization qualifying as a CHDO to claim an exemption from ad valorem taxes that would otherwise be assessed against real property owned by the organization. Tex. Tax Code Ann. § 11.182. Subsection 11.182(b) provides,

(b) An organization is entitled to an exemption from taxation of improved or unimproved real property it owns if the organization:



(1) is organized as a community housing development organization;



(2) meets the requirements of a charitable organization provided by Sections 11.18(e) and (f); (10)



(3) owns the property for the purpose of building or repairing housing on the property to sell without profit to a low-income or moderate-income individual or family satisfying the organization's eligibility requirements or to rent without profit to such an individual or family; and



(4) engages exclusively in the building, repair, and sale or rental of housing as described by Subdivision (3) and related activities.



Tex. Tax Code Ann.

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Related

Valence Operating Co. v. Dorsett
164 S.W.3d 656 (Texas Supreme Court, 2005)
Farah v. Mafrige & Kormanik, P.C.
927 S.W.2d 663 (Court of Appeals of Texas, 1996)
Nixon v. Mr. Property Management Co.
690 S.W.2d 546 (Texas Supreme Court, 1985)
TRQ Captain's Landing L.P. v. Galveston Central Appraisal District
212 S.W.3d 726 (Court of Appeals of Texas, 2006)

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Harris County Appraisal District and Harris County Appraisal Review Board v. Primrose Houston 7 Housing, L.P., Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-county-appraisal-district-and-harris-county-texapp-2007.