OPINION
JOHN S. ANDERSON, Justice.
Appellant, Public, Inc., appeals the trial court's judgment ordering appellees, Galveston County and City of Galveston, to recover from appellant taxes, penalties, and interest for the tax years 2004 through 2005 and certain special assessment liens and costs. On appeal, appellant argues appellees lacked the authority to tax appellant because appellant is a nonprofit organization exempt from paying ad valorem property taxes...
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