OPINION
YATES, Justice.
In this appeal, we decide whether TEX. TAX CODE ANN. § 21.05 (Vernon 1992) constitutes a tax exemption in violation of section 2 of article VIII of the Texas Constitution. The Appraisal Review Board of Galveston County ("the Board") and the Galveston Central Appraisal District of Galveston County (collectively "appellees") allege § 21.05 is unconstitutional. The trial court granted appellees' motion for summary judgment...
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