Richard Molina, Chief Appraiser and Cameron County Appraisal District v. QET Aircraft Services, LLC and Mario L. Arrieta Lopez

Summary

The Thirteenth Court of Appeals of Texas reviews the denial of a plea to the jurisdiction in a dispute concerning the taxation of four aircraft and an alleged exemption for non-income-producing personal property. The court holds that the taxpayers failed to exhaust administrative remedies for their exemption claims and that the chief appraiser's assessment decisions were within his statutory discretion, defeating the ultra vires claim. The court affirms limited jurisdiction to review the § 25.25(c)(3) correction motion concerning the 2022 Raytheon aircraft, reverses in all other respects, and renders judgment dismissing the remaining claims.

Holdings

1. A taxpayer seeking judicial review of a denied tax exemption must first protest the denial before the appraisal review board under Texas Tax Code section 41.41 and obtain a final ruling. Appellees did not exhaust those remedies for the claimed section 11.14 exemption, so the trial court lacked subject-matter jurisdiction over the exemption claims concerning all four aircraft for tax year 2022.
2. The trial court retained limited jurisdiction to review appellees' section 25.25(c)(3) motion concerning the 2022 Raytheon aircraft because appellees timely appealed the appraisal review board's order within sixty days. That limited jurisdiction did not extend to reviewing the denial of an exemption.
3. The trial court lacked subject-matter jurisdiction over appellees' claims seeking correction of the appraisal rolls for tax years 2023 and 2024 because the record contained no final appraisal-review-board orders addressing those claims, and appellees conceded that their notices of protest for those years were deficient.
4. Molina's determination that the aircraft were taxable was within his official and statutory authority and involved the exercise of discretion. Appellees therefore could not avoid the Tax Code's administrative-exhaustion requirements by characterizing the assessment as an ultra vires act.

Questions Presented

1. Whether appellees exhausted the administrative remedies required to obtain judicial review of the denial of a personal-property tax exemption for the aircraft.
2. Whether a motion to correct the appraisal roll under Texas Tax Code section 25.25(c)(3) permits judicial review of an exemption claim that the appraisal review board did not consider.
3. Whether the trial court had jurisdiction over appellees' claims concerning correction of the appraisal rolls for tax years 2023 and 2024 when the record contained no final appraisal-review-board orders for those years.
4. Whether Chief Appraiser Molina acted ultra vires by determining that the aircraft were taxable rather than exempt personal property.

Disposition

other