OPINION
KOEHLER, Justice.
This is an appeal from a summary judgment granted in favor of Midland Central Appraisal District and Midland County on their counterclaim for delinquent ad valorem taxes, penalties, interest and attorney's fees against General Electric Credit Corporation on its Lear Jet aircraft, and in favor of all Appellees denying double taxation relief to General Electric Credit Corporation on its petition, for the reason that it had failed...
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