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CITY OF HOUSTON v. MORGAN GUAR. INTERN. BANK

No. 01-83-0078-CV.

666 S.W.2d 524 (1983)

CITY OF HOUSTON, Houston Independent School District, and William R. Brown, Jr., Appellants, v. MORGAN GUARANTY INTERNATIONAL BANK and Morgan Guaranty Trust Company of New York, Appellees.

Court of Appeals of Texas, Houston (1st Dist.).

Rehearing Denied January 19, 1984.

Attorney(s) appearing for the Case

Larry F. York, Baker & Botts, Houston, for appellees.

James B. Cameron-Stuart, Sr. Asst. City Atty., Joan C. Ward, Asst. City Atty., Houston, for appellants.

Before EVANS, C.J., and DUGGAN and BASS, JJ.

OPINION

DUGGAN, Justice.

This is an appeal from a summary judgment enjoining the collection of city and school district ad valorem taxes on shares of a federally-chartered Edge Act corporation. Although the corporation maintains a branch office at the tax situs, its shares are wholly owned by a non-resident foreign corporation which maintains its home office in Florida.

Appellees, Morgan Guaranty International Bank ("MGIB") and Morgan Guaranty Trust...

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