Kamy Investments, LLC KAMY Trust Kozamesa Inc. Reram Inc. Amy J. Sadeghian of KAMY Real Property Trust Khosrow Sadeghian And Zachary Sadeghian of Kamy Real Property Trust v. Denton County Appraisal Review Board

CourtCourt of Appeals of Texas
DecidedAugust 1, 2024
Docket02-23-00487-CV
StatusPublished

This text of Kamy Investments, LLC KAMY Trust Kozamesa Inc. Reram Inc. Amy J. Sadeghian of KAMY Real Property Trust Khosrow Sadeghian And Zachary Sadeghian of Kamy Real Property Trust v. Denton County Appraisal Review Board (Kamy Investments, LLC KAMY Trust Kozamesa Inc. Reram Inc. Amy J. Sadeghian of KAMY Real Property Trust Khosrow Sadeghian And Zachary Sadeghian of Kamy Real Property Trust v. Denton County Appraisal Review Board) 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.

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Kamy Investments, LLC KAMY Trust Kozamesa Inc. Reram Inc. Amy J. Sadeghian of KAMY Real Property Trust Khosrow Sadeghian And Zachary Sadeghian of Kamy Real Property Trust v. Denton County Appraisal Review Board, (Tex. Ct. App. 2024).

Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-23-00487-CV ___________________________

KAMY INVESTMENTS, LLC; KAMY TRUST; KOZAMESA INC.; RERAM INC.; AMY J. SADEGHIAN OF KAMY REAL PROPERTY TRUST; KHOSROW SADEGHIAN; AND ZACHARY SADEGHIAN OF KAMY REAL PROPERTY TRUST, Appellants

V.

DENTON COUNTY APPRAISAL REVIEW BOARD, Appellee

On Appeal from the 362nd District Court Denton County, Texas Trial Court No. 23-8324-362

Before Sudderth, C.J.; Bassel and Walker, JJ. Memorandum Opinion by Justice Bassel MEMORANDUM OPINION

I. Introduction

Appellants Kamy Investments, LLC; Kamy Trust; Kozamesa Inc.; Reram Inc.;

Amy J. Sadeghian of Kamy Real Property Trust; Khosrow Sadeghian; and Zachary

Sadeghian of Kamy Real Property Trust appeal from the trial court’s order granting

the plea to the jurisdiction filed by Appellee Denton County Appraisal Review Board

(DCARB). Appellants argue in a single issue that the trial court erred by granting

DCARB’s plea to the jurisdiction because DCARB’s failure to honor the terms of the

parties’ settlement agreement—in which DCARB had agreed to “grant an ARB

protest hearing on each of [the] properties where [the] value was set without an ARB

determination of protest[,] i.e., where the notice value was set based on [Appellants’

representative’s] failure to appear for his scheduled hearing”—constituted a waiver of

governmental immunity. Because Appellants have failed to affirmatively demonstrate

the trial court’s subject-matter jurisdiction by alleging a valid waiver of immunity, we

affirm the trial court’s order granting DCARB’s plea to the jurisdiction.

II. Statutory Background

An understanding of the various phases of the Tax Code’s administrative

process is required before setting forth the dispute at issue. We therefore begin with

an overview of that process and the remedies available to taxpayers.

As recently explained by the Texas Supreme Court,

2 “The Tax Code establishes a detailed set of procedures that property owners must abide by to contest the imposition of property taxes.” Morris v. [Hous. ISD], 388 S.W.3d 310, 313 (Tex. 2012). Under Section 42.09 of the [c]ode, those “administrative procedures are ‘exclusive’ and most defenses are barred if not raised therein.” Cameron Appraisal Dist. v. Rourk, 194 S.W.3d 501, 502 (Tex. 2006). As a result, a taxpayer’s failure to exhaust the Tax Code’s exclusive administrative remedies “deprives the courts of jurisdiction to decide most matters relating to ad valorem taxes.” Id.

In general, the chief appraiser of each county appraisal district is responsible for preparing appraisal records listing all property that is taxable in the district and stating the appraised value of each. Tex. Tax Code [Ann.] § 25.01. . . . The chief appraiser “submit[s] the completed appraisal records to the appraisal review board [(ARB)] for review and determination of protests,” id. § 25.22(a), which are addressed in Chapters 41 and 42 of the [c]ode.

See Oncor Elec. Delivery Co. NTU, LLC v. Wilbarger Cnty. Appraisal Dist., Nos. 23-0138,

23-0145, 2024 WL 3075706, at *1–2 (Tex. June 21, 2024) (footnote omitted). 1

A recent decision from the Austin Court of Appeals explains how taxpayers

can appeal ARB decisions:

A property owner must first bring his complaint against an appraisal district to its ARB by way of a protest or a motion. See Tex. Tax Code [Ann.] §§ 25.25, 41.41. If the appraisal district and the property owner cannot resolve the protest or motion by agreement, the ARB is required to schedule a hearing at which the property owner is entitled to offer evidence or argument. See id. §§ 41.445, 41.45.[2] At the conclusion of

1 Because the Texas Supreme Court handed down several opinions interpreting relevant provisions of the Tax Code after the parties had submitted their briefs, we gave the parties an opportunity to file letter briefs addressing the newly issued opinions. Only DCARB filed a letter brief. 2 If a property owner is denied a protest hearing, the remedy is found in Section 41.45(f):

3 the hearing, the ARB is required to determine the protest and make its decision by written order. Id. § 41.47(a). In counties like Bastrop,[3] with a population of less than four million, the final order must be issued and delivered to the property owner no later than the thirtieth day after the date the hearing on the protest is concluded. Id. § 41.47(d), (f).[4]

Once a property owner receives notice of the ARB’s order, the property owner can appeal the substance of that decision in the following ways: by filing an appeal in district court, id. § 42.01; by appealing certain orders to an arbitrator, id. § 41A.01; or by appealing certain other orders to the State Office of Administrative Hearings, see Tex. Gov’t Code [Ann.] §§ 2003.901–.914. To challenge the procedures used by the ARB in determining their protest, property owners may request limited binding arbitration. See Tex. Tax Code [Ann.] § 41A.015. This avenue applies only to certain procedural complaints and may not be used to consider the substance of a decision. See id.

A property owner who has been denied a hearing to which the property owner is entitled under this chapter may bring suit against the appraisal review board by filing a petition or application in district court to compel the board to provide the hearing. If the property owner is entitled to the hearing, the court shall order the hearing to be held and may award court costs and reasonable attorney fees to the property owner.

Tex. Tax Code Ann. § 41.45(f). 3 The same is true for Denton County, which also has a population of less than four million. See United States Census Bureau, https://www.census.gov/quickfacts/fact/table/dentoncountytexas,US/PST045223 (last visited on July 22, 2024) (showing that Denton County had an estimated population of approximately one million as of July 1, 2023). See generally Tex. R. Evid. 201. 4 As further noted by the Austin Court of Appeals, “[t]he statute makes no exception for ARBs to delay issuing their orders because a request for limited binding arbitration is pending or arbitration is ongoing”; “only if the limited binding arbitration is successful will the order be rescinded and a new hearing held.” Johnson v. Bastrop Cent. Appraisal Dist., Nos. 03-23-00354-CV, 03-23-00404-CV, 2024 WL 3073766, at *5 (Tex. App.—Austin June 21, 2024, no pet. h.) (mem. op.) (citing Tex. Tax Code Ann. §§ 41A.015(j)(2)(B), 41.47(d), (f)).

4 Johnson, 2024 WL 3073766, at *5.

If, however, the ARB dismisses a protest because the property owner or the

owner’s agent fails to appear, the Tax Code provides relief in certain circumstances.

For instance, Section 41.45(e–1) states,

A property owner or a person designated by the property owner as the owner’s agent to represent the owner at the hearing who fails to appear at the hearing is entitled to a new hearing if the property owner or the owner’s agent files, not later than the fourth day after the date the hearing occurred, a written statement with the appraisal review board showing good cause for the failure to appear and requesting a new hearing.

Tex. Tax Code Ann. § 41.45(e–1).

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Kamy Investments, LLC KAMY Trust Kozamesa Inc. Reram Inc. Amy J. Sadeghian of KAMY Real Property Trust Khosrow Sadeghian And Zachary Sadeghian of Kamy Real Property Trust v. Denton County Appraisal Review Board, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kamy-investments-llc-kamy-trust-kozamesa-inc-reram-inc-amy-j-sadeghian-texapp-2024.