OPINION
LAGARDE, Justice.
GNB, Inc. appeals from a judgment in which the trial court upheld an order, originally made by the Collin County Appraisal District and affirmed by an appraisal review board, denying GNB's application for appraisal of certain property in Collin County as open-space land. GNB asserts in six points of error that the trial court erred by rendering judgment in favor of appellee because section 23.56(3) of the tax code
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