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NORTH ALAMO WATER SUPPLY CORP. v. WILLACY COUNTY APPRAISAL DIST.

Nos. C-8789, C-9525.

804 S.W.2d 894 (1991)

NORTH ALAMO WATER SUPPLY CORPORATION, Petitioner, v. WILLACY COUNTY APPRAISAL DISTRICT & Willacy County Appraisal Review Board, Respondents, The Honorable Dan Morales, Attorney General, State of Texas, Intervenor-Respondent. SHARYLAND WATER SUPPLY CORPORATION, Petitioner, v. HIDALGO COUNTY APPRAISAL DITRICT & Hidalgo County Appraisal District Review Board, Respondents.

Supreme Court of Texas.

Rehearing Overruled April 3, 1991.

Attorney(s) appearing for the Case

J.W. Dyer and R. Glenn Jarvis, McAllen, for North Alamo Water Supply Corp. and/or Sharyland, etc.

Russell R. Graham, Deborah S. Cartwright, Peter W. Low, and Bill Kimbrough, Austin, for Dan Morales, Atty. Gen.

Richard S. Talbert, Weslaco, for Willacy County, etc. and/or Hildalgo County, etc.

OPINION

COOK, Justice.

This court consolidated two causes for submission because both present the issue of whether a non-profit water supply corporation qualifies for exemption from ad valorem taxation as a "purely public charity" under article VIII, section 2 of the Texas Constitution and section 11.18 of the Texas Tax Code. We hold that these corporations do not fit within the constitutional definition of a "purely public charity" and, for that reason...

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