OPINION
BIERY, Justice.
The City of Laredo ("City") sued South Texas National Bank, International Bank of Commerce of Laredo and Laredo National Bank ("Banks") for delinquent ad valorem taxes on bank shares. Banks responded with a counterclaim for declaratory relief that the taxes were illegally assessed. Banks' summary judgment motions were granted and a judgment in excess of $80,000 for Banks' attorney fees...
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