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  5. 970 S.W.2d 530 (1998)
 

APPRAISAL REVIEW BD. OF GALVESTON CTY. v. TEX-AIR HELICOPTERS, INC.

No. 97-0404

970 S.W.2d 530 (1998)

APPRAISAL REVIEW BOARD OF GALVESTON COUNTY, TEXAS and Galveston Central Appraisal District of Galveston County, Texas, Petitioners, v. TEX-AIR HELICOPTERS, INC., Respondent.

Supreme Court of Texas.

Decided June 5, 1998.

Attorney(s) appearing for the Case

Patrice Pujol, Anthony P. Brown, Kenneth J. Bower, Galveston, for Petitioners.

Jack Holland, Houston, for Respondent.

GONZALEZ, Justice, delivered the opinion of the Court.

The issue in this case is whether Section 21.05 of the Tax Code unconstitutionally exempts from ad valorem taxation helicopters flown from Texas and Louisiana over international waters. In essence, Section 21.05 allows Texas tax authorities to tax only that part of a commercial aircraft's value that fairly reflects the aircraft's use in Texas. TEX. TAX CODE § 21...

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