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HIDALGO CTY. APPRAISAL DIST. v. ENGFAR N.V.

No. 13-87-241-CV.

756 S.W.2d 754 (1988)

HIDALGO COUNTY APPRAISAL DISTRICT and Hidalgo County Appraisal Review Board, Appellants, v. ENGFAR N.V. and Manfar N.V., Appellees.

Court of Appeals of Texas, Corpus Christi.

Rehearing Denied August 31, 1988.

Attorney(s) appearing for the Case

Richard S. Talbert, Weslaco, for appellants.

William F. Ikard, James Popp, Powell, Popp & Ikard, Austin, for appellees.

Before UTTER, KENNEDY and BENAVIDES, JJ.

OPINION

UTTER, Justice.

Engfar N.V. and Manfar N.V., Engfar-Manfar, brought suit against the Hidalgo County Appraisal District and the Hidalgo County Appraisal Review Board, HCAD, to appeal HCAD's denial of their applications for open-space agricultural land appraisals as provided by Tex.Tax Code Ann. ch. 23, subch. D (Vernon 1982). The trial court held that the application of Tex.Tax Code Ann. § 23.56(3) (Vernon 1982),1

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