POWERS, Justice.
Hays County Appraisal District appeals from an adverse judgment in a suit by Mayo Kirby Springs, Inc. for judicial review of a District order fixing, for ad valorem tax purposes, the market value of Mayo's real property in Hays County. See Tex.Tax Code Ann. §§ 41.21-.43 (West 1992 & Supp.1995) (the "Code"). We will reverse the trial-court judgment and remand the cause for proceedings not inconsistent with our opinion.
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