Harris County Appraisal District v. Shell Oil Co.

CourtCourt of Appeals of Texas
DecidedMay 22, 2008
Docket14-07-00106-CV
StatusPublished

This text of Harris County Appraisal District v. Shell Oil Co. (Harris County Appraisal District v. Shell Oil Co.) 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 v. Shell Oil Co., (Tex. Ct. App. 2008).

Opinion

Affirmed and Memorandum Opinion filed May 22, 2008

Affirmed and Memorandum Opinion filed May 22, 2008.

In The

Fourteenth Court of Appeals

_______________

NO. 14-07-00106-CV

HARRIS COUNTY APPRAISAL DISTRICT, Appellant

V.

SHELL OIL CO., Appellee

On Appeal from the 215th District Court

Harris County, Texas

Trial Court Cause No. 2004-52451

M E M O R A N D U M   O P I N I O N

In this tax dispute, Harris County Appraisal District (hereinafter, AHCAD@) appeals the summary judgment granted in favor of Shell Oil Co.[1] (hereinafter, AShell@) and the denial of its own cross-motion for summary judgment on the grounds that the trial court erred by: (1) failing to dismiss the suit for lack of subject matter jurisdiction; (2) granting Shell=s summary judgment motion on the basis that Harris County, an indispensable party, was not joined in the suit and that Shell waived its foreign-trade zone tax exemption as a matter of law; and (3) denying HCAD=s summary judgment motion because Shell failed to prove that it was excused from its obligation to pay ad valorem taxes as agreed with Harris County.  We affirm.

                                                                   Background

On December 15, 1993, the U.S. Department of Commerce Foreign-Trade Zones Board approved the Port of Houston Authority=s application, as grantee of Foreign-Trade Zone 84, to establish a special purpose foreign-trade subzone for the Shell refinery and petrochemical complex in Harris County.  As part of the application, Shell agreed, subject to two conditions, to forego its right of exemption under the foreign-trade zone laws with regard to Harris County ad valorem taxes for goods that are in the subzone (the A1993 Agreement@).  In consideration, Harris County agreed to not oppose the application to create the subzone.  After the subzone was established in 1993, HCAD appraised Shell=s inventory, and Shell paid ad valorem taxes to Harris County for some years.

For tax year 2004, HCAD sent Shell a notice of appraised value for its inventory with regard to Harris County ad valorem taxes.  Shell filed a written protest with the Appraisal Review Board (the AARB@) challenging HCAD=s denial of a foreign-trade zone exemption (Athe FTZ exemption@) from Harris County ad valorem taxes for inventory located in the Shell foreign-trade subzone.  After a hearing, the ARB issued its Order Determining Protest in August of 2004, denying the FTZ exemption on Shell=s inventory.  Thereafter, Shell filed suit to appeal the ARB=s order, claiming that it is entitled to the FTZ exemption.  In the trial court, Shell moved for summary judgment; HCAD responded and filed a cross-motion for summary judgment.  The trial court granted Shell=s summary judgment motion, denied HCAD=s motion, and ordered that Shell is entitled to exemption under section 11.12 of the Property Tax Code.[2]

Jurisdiction

In its first issue, HCAD contends that the trial court erred in not granting its plea to the jurisdiction.  The basis of its plea is that, according to HCAD, this case involves a contract dispute between Shell and Harris County.  Because neither HCAD=s nor ARB=s jurisdiction extends over contract rights disputes, the district court lacked subject matter jurisdiction to hear Shell=s appeal from ARB=s order. 

Shell counters that this case is a tax protest action in which it appealed HCAD=s and then ARB=s denial of an FTZ exemption for the 2004 tax year.  Shell claims that had it not appealed the denial of the requested FTZ exemption as provided by the Tax Code, the 2004 tax rolls would have become final, foreclosing Shell=s claim of the exemption for that year based on the exclusive remedies provision in the Tax Code.

Whether a court has subject‑matter jurisdiction is a question of law reviewed de novo. Tex. Dep=t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226 (Tex. 2004).

Tax Code Provisions

The Property Tax Code (the ATax Code@) creates appraisal districts and requires each district to appraise property for ad valorem tax purposes of each taxing unit within the district.  Tex. Tax Code Ann. ' 6.01 (Vernon 2008); Atascosa County v. Atascosa County Appraisal Dist., 990 S.W.2d 255, 257 (Tex. 1999).  To discharge this duty, appraisal districts must establish appraisal offices and retain chief appraisers.  Atascosa County, 990 S.W.2d at 257; see Tex. Tax Code Ann. ' 6.05 (Vernon 2008).  The Tax Code also establishes an appraisal review board for each district, which is charged with determining property owners= protests and ensuring that property is properly appraised.  See Tex. Tax Code Ann. '' 6.41, 41.01 (Vernon 2008); Atascosa County, 990 S.W.2d at 257. 

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Harris County Appraisal District v. Shell Oil Co., Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-county-appraisal-district-v-shell-oil-co-texapp-2008.