BEA ANN SMITH, Justice.
This appeal involves construing a Tax Code provision that assesses the value of a corporation surviving a merger for the purpose of imposing the state franchise tax. See Act of Apr. 2, 1985, 69th Leg., R.S., ch. 31, § 8, 1985 Tex.Gen.Laws 405, 406-07 (Tex. Tax Code Ann. § 171.153, since amended) ("Former Tax Code § 171.153"). The Comptroller interprets section 171.153(c) to require that the surviving corporation report...
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