JONES, Justice.
Park `N Fly of Texas, Inc. ("PNF"), appellee, filed suit against John Sharp, Comptroller of Public Accounts for the State of Texas, and Dan Morales, Attorney General of the State of Texas, appellants (collectively the "Comptroller"), to recover taxes paid under protest. See Tex. Tax Code Ann. ("Tax Code") § 112.052 (West 1992). After a bench trial, the trial court rendered judgment for PNF, granting declaratory relief and ordering the Comptroller...
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