Texas Judiciary Online - HTML Opinion

Opinion = issued March=20 26, 2009

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In The

Court of=20 Appeals

For The

First District=20 of Texas

NOS.=20 =20 01-08-00234-CV

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STARFLIGHT 50, L.L.C., = Appellant

HARRIS COUNTY APPRAISAL DISTRICT=20 and

HARRIS=20 COUNTY APPRAISAL = REVIEW BOARD,=20 Appellees

On Appeal from the 125th District=20 Court

Harris=20 County, Texas

Trial Court Cause No. = 2006-76682

&= nbsp; &n= bsp; &nb= sp; &nbs= p; =20 O P I N I O N

&nbs= p; =20 Starflight 50, = L.L.C.=20 (=93Starflight=94) appeals a take nothing judgment issued in favor = of the=20 Harris County Appraisal District (=93HCAD=94) and the Harris = County Appraisal=20 Review Board (=93ARB=94), rendered after a bench trial. = Starflight filed=20 suit against HCAD and the ARB in district court after the ARB = denied=20 Starflight=92s ad valorem tax protest. We decide (1) whether = Starflight properly first exhausted its administrative remedies so = as to=20 confer jurisdiction on issues of valuation, rendition, and = interstate=20 allocation, (2) whether the evidence is legally and factually = sufficient=20 to support the trial court=92s judgment, and (3) whether = Starflight waived=20 its right to allocation because it did not timely submit rendition = and=20 allocation filings to HCAD. We conclude that sufficient = evidence=20 supports the trial court=92s findings that Starflight housed its = property in=20 Texas for more than a temporary period as of the rendition date, = and that=20 the ARB properly valued the property based on the evidence = presented=20 before it. We therefore affirm.

Background

The taxable property = in dispute=20 is a = 1988=20 Dassault-Breguet (Falcon 50), SN-51V jet airplane, which = Starflight=20 purchased on March 18, 2004. Before September = 2005,=20 Starflight housed its airplane in a hangar at Lake Front Airport = in New=20 Orleans, Louisiana. On the eve of Hurricane Katrina, in late = August=20 2005, Starflight flew the airplane to Houston, where its = affiliated=20 corporation had a business operation.

Hurricane Katrina = destroyed the=20 New Orleans hangar and Starflight=92s office. Thereafter, = Starflight and its=20 personnel, including the plane=92s pilot, relocated to the Houston = area, and=20 it transacted its business out of the Houston offices of its = affiliated=20 companies. Starflight used the airplane solely to serve its=20 Houston-based affiliated companies. From September to December = 2005,=20 Starflight housed the plane at William P. Hobby Airport. At = trial,=20 Starflight maintained that, during this time and as of January 1, = 2006=20 (the date of determination for the 2005 tax year), it intended to = return=20 the airplane to the Lake Front Airport in New Orleans. =

In 2006, HCAD = discovered the=20 airplane and placed it on the tax appraisal roll for Harris = County. =20 Philip Rundle, Starflight=92s manager and the only trial witness, = testified=20 that he was responsible for tax-related issues for Starflight and = the=20 airplane. He testified that he and his partners were unaware = of=20 Harris County=92s rendition requirements, and thus they did not = render the=20 airplane before the April 15, 2006 rendition deadline.[1]=20

On August 11, 2006, = HCAD wrote=20 Starflight that the airplane was subject to ad valorem taxes and = asked=20 Starflight to provide information relevant to determining the = taxable=20 situs for the airplane for the 2005 tax year. Starflight = responded=20 with a letter dated August 22, 2006, contesting HCAD=92s appraised = value of=20 the airplane, $9,791,000.00.

On September 27, = 2006, HCAD=20 rejected Starflight=92s valuation and notified Starflight of the = airplane=92s=20 final appraised value. Starflight filed a notice of protest = of taxes=20 in Harris County on October 3, 2006, contending that the airplane = should=20 not be taxed in Harris County or in Texas. A hearing = followed,=20 attended by Mr. Rundle, wherein the ARB heard issues pertaining to = the=20 airplane=92s taxable situs. Mr. Rundle also testified that = discussion took=20 place before the ARB regarding rendition issues. On November = 27,=20 2006, the ARB denied Starflight=92s protest. Starflight = appealed the=20 ARB order to the trial court, which rejected it.

Discussion

I. =20 Jurisdiction

At the outset, HCAD = contends=20 that Starflight failed to exhaust its administrative remedies with = respect=20 to its complaints of valuation, rendition and allocation because=20 Starflight did not contest these issues on its protest form and = did not=20 raise them before the ARB.[2] =20 Thus, as a threshold matter, we determine whether we have = jurisdiction=20 over the appeal. Kilroy v. Kilroy, 137 S.W.3d 780, 783 = (Tex.=20 App.=97Houston [1st Dist.] 2004, no pet.)).

=20 A. Standard of=20 Review

=20 District courts in Texas have general jurisdiction to hear and = decide=20 suits, absent statutory exception. See Tex. Const. art. V., = =A7 8;=20 Appraisal Rev. Bd. of Harris County Appraisal Dist. v. = O=92Connor &=20 Assocs., 267 S.W.3d 413, 416 (Tex. App.=97Houston [14th = Dist.]=20 2008, no pet.) (citing Subaru of Am., Inc. v. David McDavid = Nissan,=20 Inc., 84 S.W.3d 212, 220 (Tex. 2002)). An administrative = agency,=20 however, has exclusive jurisdiction to decide matters within its = purview=20 if a pervasive regulatory scheme indicates that the Legislature = intends=20 for the regulatory process to be the exclusive forum to settle=20 disputes. Id. (citing Subaru, 84 S.W.3d = at=20 221). If an agency has exclusive jurisdiction, a party must=20 typically exhaust any administrative remedy before seeking = judicial review=20 of the agency=92s action. Id. The Tax Code is a = pervasive=20 regulatory scheme, vesting the ARB with exclusive original = jurisdiction=20 over property tax appraisals. O=92Connor & = Assocs., 267=20 S.W.3d at 416=9617. In the Property Tax = Code,=20 the=20 exhaustion of = remedies provisions, found in section=20 42.09, are = mandatory=20 and jurisdictional. Koll = Bren Fund VI,=20 LP v. Harris County Appraisal Dist., No. 01-07-00321-CV, 2008 = WL=20 525799, at *4 (Tex. App.=97Houston [1st Dist.] Feb. 28, 2008, pet. = denied)=20 (mem. op.); see Tex. Tax=20 Code Ann. =A7 42.09 (Vernon 2008). A = trial court thus = lacks subject=20 matter jurisdiction, and must dismiss the claims within the = agency=92s=20 exclusive jurisdiction, until the party seeking relief exhausts = all of its=20 administrative remedies. O=92Connor & Assocs., = 267 S.W.3d=20 at 416. Accordingly, before seeking relief in district = court,=20 Starflight must have exhausted its administrative remedies.=20 Id.

B. Matters = raised before=20 the ARB

Starflight protested = that=20 Harris County was not the taxable situs for its airplane, sent = HCAD a=20 letter dated August 22, 2006, disputing HCAD=92s appraised value = of the=20 airplane, attended the ARB, and received an order from the ARB = denying its=20 protest. See Tex. Tax=20 Code Ann. =A7=A7 41.41(A) (Vernon 1999), 41.43 (Vernon = 2007),=20 42.01(1)(A) (Vernon 1998); O=92Connor &=20 Assocs., 267=20 S.W.3d at 416. We have no record of = the=20 protest proceeding, but note that HCAD=92s counsel admitted to the = trial=20 court that as a practical matter the ARB panel would have = considered=20 issues of valuation and timely rendition of allocation information = during=20 Starflight=92s proceeding.

Because Starflight = filed its=20 protest in accordance with the Tax Code and because the ARB = considered the=20 substantive matters ultimately appealed to the district court, we = hold=20 that Starflight exhausted its remedies as to these matters, = obtained an=20 order denying them, and thus could seek judicial review of the ARB = order. Zapata County Appraisal Dist. v. Coastal Oil & = Gas=20 Corp., 90 S.W.3d 847, 851 (Tex. App.=97San Antonio, 2002 pet. = denied);=20 O=92Connor & Assocs., 267 S.W.3d at 417 (citing = MAG-T, L.P. v.=20 Travis Cent. Appraisal Dist., 161 S.W.3d 617, 624 (Tex. = App.=97Austin=20 2005, pet. denied)); see Tex.=20 Tax Code Ann.=20 =A7 42.23(a) (Vernon 2005). The trial court therefore = properly=20 asserted subject matter jurisdiction over this suit. = O=92Connor=20 & Assocs., 267 S.W.3d at 417.

II. =20 Legal and Factual Sufficiency

First, Starflight = complains=20 that the trial court=92s finding of fact that it housed its = airplane in=20 Harris County, Texas, as of January 1, 2006, on more than a = temporary=20 basis, is against the overwhelming weight and evidence so as to be = manifestly unjust.

A. =20 Standard of Review

We review the trial = court=92s=20 findings for legal and factual sufficiency of the evidence using = the same=20 standards we apply in reviewing evidence supporting a jury=92s=20 verdict. Aguiar v. Segal, 167 S.W.3d 443, 449 (Tex.=20 App.=97Houston [14th Dist.] 2005, pet. denied); see = Davis=20 v. City of Austin, 632 S.W.2d 331, 333 (Tex. 1982). A = party who=20 attacks the legal sufficiency of an adverse finding on an issue on = which=20 that party has the burden of proof must demonstrate on appeal that = the=20 evidence establishes, as a matter of law, all vital facts in = support of=20 the issue. Dow Chem. Co. v. Francis, 46 S.W.3d 237, = 241 (Tex.=20 2001).

In=20 determining whether legally sufficient evidence supports the = finding under=20 review, we must consider evidence favorable to the finding if a = reasonable=20 fact finder could consider it, and disregard = evidence=20 contrary to the finding unless a reasonable fact finder could not=20 disregard it. City of Keller v. = Wilson,=20 168 S.W.3d 802, 827=20 (Tex. = 2005).=20 When=20 a party attacks the factual sufficiency of an adverse finding on = an issue=20 on which that party had the burden of proof, that party must show = on=20 appeal that the adverse finding is against the great weight and=20 preponderance of the evidence. Francis, 46 S.W.3d at = 242.=20

B. = Analysis =20

Texas Tax Code = section 11.01(c)=20 provides that the State of Texas has jurisdiction to tax tangible = personal=20 property = located=20 in this state for longer than a temporary period, unless exempt by = law. The determination whether property is located within a = taxing=20 unit depends upon the facts of the case. City of Dallas = v.=20 Overton, 363 S.W.2d 821, 825 (Tex. Civ. App.=97Waco 1963, writ = ref=92d=20 n.r.e.) (holding that the question of whether or not the property = in=20 question is =93more or less permanent=94 depends upon factual = situation in=20 each case); see also Lawson v. Groves, 487 S.W.2d = 439, 442=20 (Tex. Civ. App.=97Beaumont 1972, no writ) (holding that question = of tax=20 situs is factual and dependent on situation in each case). = The=20 determination of whether property is located within a taxing unit = depends=20 on the status of the property as of January 1 of the following = year. =20

In reviewing the = record for=20 evidence as to whether the plane was more or less permanent, the = following=20 evidence supported the trial court=92s finding that Starflight=92s = airplane=20 was present in Harris County, Texas for more than a temporary = period as of=20 January 1, 2006:

=B7 =20 Starflight=92s = August 22, 2006=20 letter to HCAD admitted that = =93the . . . aircraft=20 was relocated from Louisiana to Texas after Hurricane = Katrina. As of=20 01/01/06, this aircraft was located in Harris County, Texas[,]=94 = and=20 Starflight=92s trial witness testified to the same;

=B7 =20 Starflight housed = its plane at=20 Hobby Airport, in Harris County, Texas after Hurricane Katrina;=20

=B7 =20 After September 1, = 2005,=20 Starflight entered into a non-written agreement with Enterprise = Aviation=20 at Houston=92s Hobby Airport to house the plane;

=B7 =20 Starflight=92s plane = served only=20 the owners and partners of its Houston affiliates exclusively, and = did not=20 charter to any other parties;

=B7 =20 Starflight=92s = owners and=20 affiliate corporation have had a place of business in Houston = since=20 2002;

=B7 =20 Hurricane Katrina = destroyed=20 Starflight=92s New Orleans hangar, the hangar was not = rebuilt;

=B7 =20 Starflight=92s = employees,=20 including the plane=92s pilot, relocated to Houston after = Hurricane=20 Katrina;

=B7 =20 Starflight admitted = =93[t]he=20 aircraft was being hangared at Hobby Airport . . . until adequate = hangar=20 space can be built in New Orleans=94;

=B7 =20 Starflight=92s = flight log,=20 though never submitted to the ARB, reflected that it was used = regularly in=20 Harris County where a majority percentage of the plane=92s 2005 = flights=20 departed from Houston;

=B7 =20 Starflight offered = no=20 documentation at trial indicating its business transactions = occurring at=20 offices other than the Houston addresses of its affiliated = companies or=20 that it rendered the plane for tax purposes at any other=20 locale; =

=B7 =20 Starflight=92s New = Orleans=20 office maintained pilot log books, aircraft maintenance records = and=20 paperwork; and after Hurricane Katrina, such documents were = maintained at=20 the pilot=92s house in Texas;

=B7 =20 As of January 1, = 2006, the=20 airplane remained at Houston=92s Hobby Airport as part of a lease = agreement=20 Starflight had executed to store the plane; and

=B7 =20 Starflight is a = corporation=20 authorized to do business under the laws of the State of = Texas.

We hold that this = evidence is=20 legally sufficient to support the trial court=92s finding that the = airplane=20 was not kept in Harris County, Texas purely on a temporary = basis. =20 Overton, 363 S.W.2d at 826 (holding that where planes = received=20 servicing and maintenance at Addison, remained available there for = owner=92s=20 business trips, and when such trips are completed, they are = returned to=20 Addison, planes are not =93temporarily=94 kept at Addison). =

Although relocation = to Houston=20 was unplanned, unintended, and unavoidable, the course of events = following=20 the storm overshadowed Starflight=92s intention, and the plane=92s = removal to=20 Houston was something more than temporary. The Texas Supreme = Court=20 has held that a party=92s intentions and preparatory acts are = legally=20 insufficient evidence to establish a plane=92s situs for tax = purposes in the=20 face of objective facts demonstrating it. See = Davis=20 v. City of Austin, 632 S.W.2d 331, 334 (Tex. = 1982). =20

In a factual = sufficiency=20 review, we consider all of the evidence presented on tax situs, = including=20 Rundle=92s testimony that Starflight did not intend to house the = plane in=20 Harris County permanently. Aside from Rundle=92s testimony, = however, nothing=20 in the record shows the plane=92s return to Louisiana as of = January 1,=20 2006. In light of the other evidence presented, we hold that = factually sufficient evidence supports the trial court=92s = finding. =20

III. =20 Rendition and Allocation

Second, Starflight = complains=20 that the district court erred in holding that Starflight failed to = timely=20 render the property and thus waived its right to an allocation and = that it=20 failed to adjudicate the issue of allocation. Starflight in=20 particular appeals the trial court=92s conclusions of law = pertaining to=20 rendition and allocation, which state:

7. = ; =20 Rendition of the = airplane,=20 including allocation information, if any, was = mandatory.

8. = ; =20 Under 34 Texas = Administrative=20 Code Ann., Section 9.4033 rendition requires that the owner = provide enough=20 information necessary to prove the entitlement to allocation and = to permit=20 the chief appraiser to apply an allocation formula appropriate to = the=20 airplane. For the year 2006 the rendition must have been provided = by April=20 15, 2006.

9. = ; =20 The chief appraiser = of HCAD=20 has the nondiscretionary duty to include the airplane on the 2006=20 appraisal roll.

10. = ;=20 The airplane was not = and has=20 not been rendered by Starflight for the tax year 2006.

11. = ;=20 The plaintiff should = recover=20 nothing against the defendants in this case.

A. Standard of = Review

We review de = novo a=20 trial court=92s conclusions of law, and we uphold the judgment if = it can be=20 sustained on any legal theory supported by the evidence. =20 Holloway-Houston, Inc. v. Gulf Coast Bank & Trust Co., = 224=20 S.W.3d 353, 357 (Tex. App.=97Houston [1st Dist.] 2006, no pet.) = (citing=20 BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789, 794 = (Tex.=20 2002)); In re Moers, 104 S.W.3d 609, 611 (Tex. = App.=97Houston [1st=20 Dist.] 2003, no pet.). An appellant may not challenge a = trial=20 court=92s conclusions of law for lack of factual sufficiency, but = we review=20 the legal conclusions drawn from the facts to determine their=20 correctness. Holloway-Houston, 224 S.W.3d at 357 = (citing=20 BMC Software, 83 S.W.3d at 794).

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=20

Rendition =93is the = reporting of=20 taxable property by the owner to the appraiser=94 and is thus = procedural in=20 nature. Harris County Appraisal Dist. v. Texas Gas Transmission = Corp., 105 S.W.3d 88, 94 (Tex. App.=97Houston [1st Dist.] = 2003, pet.=20 denied) (en banc). Section 22.01(a) of the Tax Code requires = that an=20 owner of tangible personal property used to produce income shall = render=20 the property for taxation on January 1 of the tax year. = See=20 Tex. Tax Code = Ann.=20 =A7 22.01(a) (Vernon 2008). The word =93shall=94 in = section 22.01(a)=20 is mandatory, not discretionary. Texas Gas Transmission=20 Corp., 105 S.W.3d at 91 (citing Robinson v. Budget = Rent-A-Car Sys.,=20 Inc., 51 S.W.3d 425, 430=9631 (Tex. App.=97Houston [1st Dist.] = 2001, pet.=20 denied)).

=20 A taxpayer must file its rendition form after January 1 and not = later than=20 April 15. See Tex.=20 Tax Code Ann. =A7 22.23(a). Upon written request by = the=20 property owner, the chief appraiser shall extend the deadline to = May 15,=20 and for good cause shown in writing may further extend the = deadline an=20 additional 15 days. See id. =A7 22.23(a) and = (b). In an=20 effort to encourage timely filings, in 2003 the Texas Legislature = enacted=20 section 22.28, which imposes a mandatory penalty of 10 percent of = the=20 property=92s final appraised value for late filing of a rendition=20 statement.[3] =20 See id. =A7 22.28(a). =20 =

Starflight first = argues that=20 its failure to render was the result of HCAD=92s failure to = publicize Harris=20 County=92s rendition requirements. Starflight offers no = support from=20 the record for its contention that HCAD failed to meet its notice=20 requirements under section 22.21 of the Tax Code, and it did not = offer any=20 authority for its theory that such failure is a legal defense or = condition=20 precedent to Starflight=92s non-compliance with section = 21.01(a). =20 Tex. R. App. P. = 38.1(h);=20 Tex. Tax Code = Ann. =A7=20 22.21(a); Sterner v. Marathon Oil Co., 767 S.W.2d 686, = 689=9690 (Tex.=20 1989). We hold that Starflight waived this issue on = appeal. =20 Tex. R. App. P.=20 38.1(h).

Starflight next = argues that its=20 August 22, 2006 letter constitutes a rendition statement. = Both=20 Starflight and HCAD agree that Starflight did not file a rendition = statement by April 15, 2006 under section 22.23(a). = Starflight never=20 requested or received permission to late file a rendition = statement under=20 section 22.23(b). Starflight=92s only trial witness = testified=20 that =93I don=92t think it=92s ever been=20 rendered . . . .=94 The trial court = concluded that=20 Starflight filed no rendition statement for tax year 2006. = We hold=20 that legally sufficient evidence supports the trial court=92s = conclusion of=20 law that Starflight did not timely render the property for the = 2006 tax=20 year.

Starflight further = contends=20 that, as to its August 22, 2006 =93late filed rendition=94 letter, = the late=20 filing does not bar it from seeking interstate allocation of the = value of=20 the plane for the time Starflight used it outside Texas. = Even if we=20 assume that Starflight=92s August 22 letter constituted a = rendition filing,=20 Starflight did not submit any allocation information with the = letter and=20 did not submit any allocation information until December = 2006. Tex. Tax Code Ann. = =A7=A7 21.01(a)=20 (Vernon 2006), 21.055 (Vernon 2008).

=93Allocating=94 is = determining the=20 ratio of usage of personal property within each taxable situs when = the=20 property has more than one taxable situs. Texas Gas = Transmission=20 Corp., 105 S.W.3d at 91 n.3. The owner of an airplane = used for=20 business purposes may seek a reduction in the amount of total = taxes owed=20 upon the airplane by showing that another state or jurisdiction = has=20 acquired the right to tax the same airplane. Tex. Tax Code Ann. = =A7=A7 21.03,=20 21.055 (Vernon 2008); Appraisal Rev. Bd. of Galveston County v. = Tex-Air=20 Helicopters, Inc., 970 S.W.2d 530, 534 (Tex. 1998). The = actual=20 taxes owed in Texas on a business airplane thus will be reduced=20 proportionately to reflect the amount of use in Texas, and the = appraisal=20 office shall allocate to this state the portion of the total = market value=20 of the property to fairly reflect its use in this state. = See=20 Tex. Tax Code = Ann.=20 =A7=A7 21.03(a), (b)(1), (b)(2); Texas Gas Transmission = Corp., 105=20 S.W.3d at 91 n.3.

In Texas Gas we = held that=20 a taxpayer who seeks allocation under the Tax Code must provide=20 information showing entitlement to allocation at the time of=20 rendition. Texas Gas Transmission Corp., 105 = S.W.3d at=20 94 (=93[A] taxpayer claiming entitlement to allocation must = provide=20 supporting information when he submits his rendition form.=94); = SLW=20 Aviation, Inc. v. Harris County Appraisal Dist., 105 S.W.3d = 99, 102=20 (Tex. App.=97Houston [1st Dist.] 2003, no pet.). Starflight = argues=20 that allocation is a constitutional entitlement; nevertheless, = even a=20 constitutional entitlement to allocation can be waived when a = party fails=20 to follow the implementing legislation. Aramco Assoc=92d = Co. v.=20 Harris County Appraisal Dist., 33 S.W.3d 361, 364 (Tex. = App.=97Texarkana=20 2000, pet. denied).

Under Aramco = and=20 Texas Gas, it is not Starflight=92s failure to render which = waived=20 any interstate allocation. Instead, it was Starflight=92s failure = to file=20 any allocation information contemporaneously with a rendition = statement=20 which precluded its argument for allocation in the trial court.=20 Texas Gas Transmission Corp., 105 S.W.3d at 94. = Starflight=92s failure to submit allocation information until = December 2006=20 did not meet its burdens under Texas Gas, Aramco or=20 statutory law to establish an entitlement to allocation. = Tex. Tax Code Ann. = =A7=A7 21.055,=20 22.01(a); Tex. Admin. = Code=20 =A7 9.4033(e); Texas Gas Transmission Corp., 105 S.W.3d at = 93.=20

Having failed to meet = its=20 burden, the district court properly found in its conclusions of = law that=20 Starflight did not provide information from which HCAD could have=20 determined entitlement to allocation and thus failed to prove its=20 entitlement to allocation. Aramco, 33 S.W.3d at = 364; Texas=20 Gas Transmission Corp., 105 S.W.3d at 93=9694.

Starflight argues = that it=20 submitted allocation information to HCAD when it filed its appeal = of the=20 ARB order in the trial court and that because the trial court=92s = review is=20 de novo[4]=20 the trial court erred in not adjudicating the issue of = allocation. =20 Starflight contends that =93[a]ll parties agree HCAD received = sufficient=20 information to enable it to allocate the Airplane=92s use in late = December=20 2006, when Starflight filed suit in district court.=94 But, = as the=20 trial court found and as we have discussed, such submission was = not filed=20 with rendition and came too late. See Tex.=20 Tax Code Ann. =A7=A7=20 22.01(a), 21.055; Tex.=20 Admin. Code =A7=20 9.4033(e); Texas Gas Transmission Corp., 105 S.W.3d at = 93. =20 Thus, we hold Starflight waived its right to allocation. = See=20 Texas Gas Transmission, 105 S.W.3d at 93=9694; Aramco, = 33 S.W.3d=20 at 364.

Conclusion

=20 Having considered Starflight=92s issues on appeal, we affirm = judgment of the=20 trial court.

&= nbsp; &n= bsp; &nb= sp; &nbs= p; = ; =20 Jane Bland

&= nbsp; &n= bsp; &nb= sp; &nbs= p; = ; =20 Justice

Panel consists of = Justices=20 Jennings, Hanks and Bland.

Justice Jennings,=20 dissenting.

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