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STRAYHORN v. WILLOW CREEK RESOURCES, INC.

No. 03-04-00629-CV.

161 S.W.3d 716 (2005)

Carol Keeton STRAYHORN, Comptroller of Public Accounts of the State of Texas and Greg Abbott, Attorney General of the State of Texas, Appellants v. WILLOW CREEK RESOURCES, INC., Appellee.

Court of Appeals of Texas, Austin.

March 24, 2005.

Attorney(s) appearing for the Case

Blake A. Hawthorne, Asst. Atty. Gen., Austin, for Appellants.

Mark W. Eidman, Ray Langenberg, Scott, Douglass & McConnico, LLP, Austin, for Appellee.

Before Chief Justice LAW, Justices B.A. SMITH and PEMBERTON.

OPINION

BEA ANN SMITH, Justice.

In this case, we determine whether the informal review of a tax-refund claim provided by tax code section 111.1042 tolls the statute of limitations for filing that claim. See Tex. Tax Code Ann. § 111.1042 (West Supp.2004-05). To do this, we must construe the term "administrative proceeding," as it was used in tax code section 111.207(d),1

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