OPINION
ARNOT, Chief Justice.
Gregory Lloyd Sandefur owned an undivided nonparticipating royalty interest in Section 158, H & TC Railway Survey in Taylor County, Texas. Production was established on this land subject to the terms of an oil, gas, and mineral lease. Ad valorem taxes were assessed against Sandefur's producing royalty interest pursuant to TEX. PROP. TAX CODE ANN. § 32.01 (Vernon Supp.1998). These taxes were not paid. The proceeds attributable...
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