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ALL AMERICAN LIFE INS. CO. v. RYLANDER

No. 03-00-00427-CV.

73 S.W.3d 299 (2001)

ALL AMERICAN LIFE INSURANCE COMPANY; American General Life Insurance Company; American National Insurance Company; American National Life Insurance Company of Texas; IDS Life Insurance Company; and USLIFE Life Insurance Company, Appellants, v. Carol Keeton RYLANDER, Comptroller of Public Accounts of Texas; and John Cornyn, Attorney General of Texas, Appellees.

Court of Appeals of Texas, Austin.

August 30, 2001.

Attorney(s) appearing for the Case

Barry Bishop, Clark, Thomas & Winters, Austin, for appellant.

William E. Storie, Assistant Attorney General, Taxation Division, Austin, for appellee.

Before Justices KIDD, B.A. SMITH and PURYEAR.

PURYEAR, Justice.

Several insurance companies sued the Comptroller and the Attorney General (collectively, "the State") to recover premium and maintenance taxes assessed by the Comptroller under the insurance code on internal rollover transactions. Tex. Ins.Code Ann. arts. 4.11 & 4.17 (West Supp.2001). The district court entered a take-nothing judgment against the companies. The companies complain that the trial court did not properly construe the tax statutes...

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