OPINION
KLINGEMAN, Justice.
This is a suit by the National Bank of Commerce (Bank) against the City of San Antonio (City) and the San Antonio Independent School District (School District) for recovery of an alleged overpayment of ad valorem taxes for the year 1976. The Bank sought a refund contending an overpayment was made through a mutual mistake. The trial court judgment, based on the jury's verdict,
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