OPINION
GONZALEZ, Justice.
This is an appeal of an ad valorem tax dispute. Cherokee Water Company, the taxpayer, challenged the valuation of certain interests in land in Gregg and Rusk Counties for the tax years 1982, 1983, 1985, and 1986. The trial court rendered judgment setting a lower fair market value than the appraised value set by Gregg County Appraisal District
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