23-0149·Petition For Review
- A taxpayer suing the Comptroller for a sales-tax refund in district court must prove entitlement to an exemption by a preponderance of the evidence, not by clear and convincing evidence, because the Tax Code provides for trial de novo and the Comptroller's rule applies only to the administrative process.
- A private, for-profit prison operator that contracts with governments to house inmates is not an "agent" or "instrumentality" of the federal or state government exempt from sales and use tax on its purchases.
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23-0875·Petition For Review
- A former owner cannot set aside a subsequent purchaser's title on due-process grounds, even after a defective tax-suit citation by publication, if she received notice of the default judgment or of the property's sale during the two-year statutory period to redeem or sue, because she then had an adequate remedy at law.
- A subsequent purchaser may also raise equitable defenses such as laches against a former owner who learned of the judgment or sale after limitations ran but unreasonably delayed, to the purchaser's detriment; because the record did not show when the owner received notice, the Court affirmed the remand.
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24-0037·Petition For Review
- Section 171.103(a)(1) sources franchise-tax receipts from goods to Texas when the seller yields possession and control to a buyer at a location in Texas, even if the buyer takes the goods elsewhere for use, so Comptroller rules making the transfer point determinative are valid.
- NuStar's bunker-fuel sales delivered to foreign-registered vessels at Texas ports were properly sourced to Texas.
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24-0052·Petition For Review
- RJR Vapor's VELO oral nicotine pouches are taxable "tobacco product[s]" because they are "made of . . . a tobacco substitute": non-tobacco plant matter and nicotine take the place and function of tobacco in expressly taxed products.
- The Court rendered judgment that the pouches are taxable and remanded for the court of appeals to consider RJR's constitutional challenge.
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24-0782·Petition For Review
- Individual Willacy County taxpayers have standing to contest South Texas ISD's ad valorem tax, and the court of appeals erred by relying on a taxpayer-standing doctrine that does not fit their claim; a school district in the county lacks standing.
- The Court remanded for the court of appeals to decide whether other jurisdictional hurdles bar the taxpayers' claims.
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25-0754·Mandamus
- The Court denied an emergency petition for writ of mandamus challenging the ballot language for the Austin City Council's November 2025 property-tax-increase election, and Justice Young issued a statement calling the question close but saying the denial is no precedent or endorsement of the language.
- The statement noted the ballot's purpose clause lists specific programs but adds a catchall for other general fund expenditures, that a tax increase compounds in later years' voter-approval rates, and that the Court may need to give further guidance once new legislation on ballot language, S.B. 506, is tested.
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25-1093·Petition For Review
- Did ENGIE IR and the school district plead a viable ultra vires claim against the Comptroller for withdrawing a Chapter 313 certificate after the Comptroller's review deadline and after the statute expired, even though the court of appeals found the withdrawal unauthorized but "harmless"?
- Was the certificate invalid from the start because the applicant merged before it issued, and can a withdrawal that may have been unauthorized still support an ultra vires claim in that case?
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26-0060·Petition For Review
- Does Tax Code § 42.29, which says a prevailing property owner "may be awarded" reasonable attorney's fees, make the award discretionary or mandatory, and was the owners' fee evidence legally sufficient?
- After Texas Disposal Systems Landfill v. Travis Central Appraisal District held market-value evidence admissible in equal-and-uniform cases, must the case be retried because the trial court excluded the district's evidence of sales prices?
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26-0153·Petition For Review
- Is crude oil stored in San Patricio County tanks before export exempt from ad valorem taxation under the Import-Export Clause, as incorporated by Tax Code § 11.12, or is it taxable because a constant, substantial quantity is present and it is not merely passing through Texas?
- Does the Court's decision in Virginia Indonesia Co. v. Harris County Appraisal District ("VICO") and its stream-of-export rule control, or does the Supreme Court's Michelin Tire framework permit a nondiscriminatory property tax on oil awaiting export?
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26-0157·Petition For Review
- Is crude oil stored in San Patricio County tanks before export exempt from ad valorem taxation under the Import-Export Clause, as incorporated by Tax Code § 11.12, or is it taxable because a constant, substantial quantity is present and it is not merely passing through Texas?
- Does the Court's decision in Virginia Indonesia Co. v. Harris County Appraisal District ("VICO") and its stream-of-export rule control, or does the Supreme Court's Michelin Tire framework permit a nondiscriminatory property tax on oil awaiting export?
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