OPINION
McDONALD, Chief Justice.
This is an appeal by Grandview ISD from judgment finding its 1971 through 1977 tax assessments on 197 acres owned by John W. Storey and wife, based on market value rather than agricultural value, void; and decreeing the Storeys pay taxes based on the agricultural value in the sum of $2,782.68.
Grandview ISD filed this suit against the Storeys for delinquent taxes on real and
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