Hunt County Appraisal District v. Lake Tawakoni Wind Point Park Corporation

CourtCourt of Appeals of Texas
DecidedOctober 28, 2024
Docket06-24-00016-CV
StatusPublished

This text of Hunt County Appraisal District v. Lake Tawakoni Wind Point Park Corporation (Hunt County Appraisal District v. Lake Tawakoni Wind Point Park Corporation) 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
Hunt County Appraisal District v. Lake Tawakoni Wind Point Park Corporation, (Tex. Ct. App. 2024).

Opinion

In the Court of Appeals Sixth Appellate District of Texas at Texarkana

No. 06-24-00016-CV

HUNT COUNTY APPRAISAL DISTRICT, Appellant

V.

LAKE TAWAKONI WIND POINT PARK CORPORATION, Appellee

On Appeal from the 196th District Court Hunt County, Texas Trial Court No. 91947

Before Stevens, C.J., van Cleef and Rambin, JJ. Memorandum Opinion by Justice Rambin MEMORANDUM OPINION

Lake Tawakoni Wind Point Park Corporation (LT Corp.) filed a lawsuit challenging two

orders determining its protests for taxes on improvements assessed by the Hunt County

Appraisal District (HCAD) for the 2022 and 2023 tax year. See TEX. TAX CODE ANN. §§ 42.01,

42.21 (Supp.). In its lawsuit, LT Corp. complained that the HCAD improperly assessed property

taxes on improvements made to property belonging to the Sabine River Authority (Sabine), an

entity exempted from paying ad valorem property taxes. In response, the HCAD noted that

Sabine had granted LT Corp. a permit to manage, operate, and maintain the improvements and

argued it was taxing LT Corp.’s leasehold or possessory interest in the property and not Sabine’s

property. Following cross-motions for summary judgment, the trial court agreed with LT Corp.,

granted its traditional motion for summary judgment on the issue, and entered a final judgment

finding that the HCAD’s assessments were “not taxable to [LT Corp.] in tax years 2022 and

2023.”

On appeal, the HCAD argues that the trial court erred by granting LT Corp.’s motion for

summary judgment while denying its motion for summary judgment. Because we find that LT

Corp.’s permit was a license, not a leasehold or possessory interest in land, we conclude that the

trial court’s summary judgment rulings were proper. As a result, we affirm the trial court’s

judgment.

I. Factual Background

The Sabine River Authority was created in 1949. It is undisputed that Sabine is a

political subdivision of the State. See TEX. CONST. art. XVI, § 59; City of Dallas v. Sabine River

2 Auth. of Tex., No. 03-15-00371-CV, 2017 WL 2536882, at *1 (Tex. App.—Austin June 7, 2017,

no pet.) (mem. op.). Section 11.11(a) of the Texas Tax Code exempts “property owned by this

state or a political subdivision of this state . . . from taxation if the property is used for public

purposes.” TEX. TAX CODE ANN. § 11.11(a). The Texas Constitution also contains an

exemption from taxation for public property used for public purposes. See TEX. CONST.

art. VIII, § 2.

It is also undisputed that Sabine owns the fee interest in Lake Tawakoni Wind Point Park

(Park), a “180[-]acre recreational park operated and open for public use in Hunt County.” In

years past, Sabine used to handle the “day-to-day maintenance and operation of recreational

facilities at the Park.” More recently in its history, Sabine took advantage of the Texas

Legislature’s grant to districts, like Sabine,1 of permission to contract with third parties “for the

joint construction . . . and operation of any works, [or] improvements,” or for the “performance

of any purpose or function permitted by a district.” TEX. WATER CODE ANN. § 49.213(a)–(b);

see Kirby Lake Dev., Ltd. v. Clear Lake City Water Auth., 320 S.W.3d 829, 836 (Tex. 2010). “A

district may [also] lease any of its property, real or personal, to any person.” TEX. WATER CODE

ANN. § 49.225.

The affidavit of Ryan Fergus, LT Corp.’s president, established that LT Corp. underwent

a proposal process in response to Sabine’s request for bidders to operate the Park. In 2014,

Sabine granted LT Corp. a “Commercial Limited Use Permit” (Permit) to “establish, operate,

and maintain a recreational land use operation in accordance with the Permitted Use,” which was

1 Sabine qualifies as a district for purposes of the Texas Water Code. See TEX. WATER CODE ANN. § 49.001(a)(1); Pitts v. Sabine River Auth. of Tex., 107 S.W.3d 811, 813 (Tex. App.—Texarkana 2003, pet. denied). 3 defined as “Recreational/RV Park.” See id. The Permit allowed LT Corp. to “[u]tilize the [Park]

in strict accordance with the Permitted Use and none other.” It also stated that “[a]ll

improvements and/or alterations to the [Park] must be approved in writing by [Sabine].”

According to LT Corp., the HCAD had never taxed anyone on the improvements made to

the Park until the 2022 tax year, when it sent LT Corp. a $48,743.50 bill for taxes assessed on the

value of improvements to the Park. Taxes were also assessed by the HCAD for the 2023 tax

year. LT Corp. filed protests with the Hunt County Appraisal Review Board but failed to

succeed on its claim that no taxes should have been assessed. See TEX. TAX CODE ANN.

§ 41.41(a)(1) (Supp.).

After filing its lawsuit, LT Corp. filed a motion for summary judgment, which had

attached as evidence the Permit and the affidavit of David Montagne, the executive vice

president and general manager of Sabine, both of which showed that Sabine owned the real

property where the Park was situated. Montagne added that LT Corp. “ha[d] performed its

duties under the Permit for the benefit of [Sabine] and in place of [Sabine] performing th[o]se

exact duties itself as required to operate the Park for public purposes.”

The HCAD filed its own motion for summary judgment, arguing that it was not taxing

Sabine’s interest in the Park, only LT Corp.’s “leasehold or possessory interest,” which was not

owned by Sabine. That argument was made pursuant to Section 25.07(a) of the Texas Tax Code,

which states, “[A] leasehold or other possessory interest in real property that is exempt from

taxation to the owner of the estate . . . shall be listed in the name of the owner of the possessory

interest if the duration of the interest may be at least one year.” TEX. TAX CODE ANN. § 25.07(a)

4 (Supp.). HCAD further argued that LT Corp. was a “private, for-profit corporation” that

accepted fees for the public’s use of the Park and its amenities.

LT Corp. responded to HCAD’s argument by stating that it merely had a limited license

with respect to the property, not any leasehold or possessory interest. LT Corp. attached its

appraisal card showing that HCAD had listed the property being taxed as “Improvement[s],”

including improvements it described as an office, boat dock, and RV sites, among others.

After hearing the parties’ arguments, the trial court granted LT Corp.’s motion for

summary judgment, denied HCAD’s motion, and ordered the HCAD to (1) correct the appraisal

roll to reflect that the Park “is not taxable to [LT Corp.] in tax years 2022 and 2023; and

(2) refund [LT Corp.] . . . the full amount of all tax[es] paid by [it].”2

II. Standard of Review and Applicable Law

An appellate court reviews de novo the grant or denial of a motion for summary

judgment. Mann Frankfort Stein & Lipp Advisors, Inc. v. Fielding, 289 S.W.3d 844, 848 (Tex.

2009). “The party moving for traditional summary judgment bears the burden of showing no

genuine issue of material fact exists and it is entitled to judgment as a matter of law.” State

Farm Mut. Auto. Ins. Co. v. Rumbaugh, 642 S.W.3d 901, 903 (Tex. App.—Texarkana 2022, pet.

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