OPINION
G. ALAN WALDROP, Justice.
Appellees the State of Texas, the City of Dallas, Texas, and the Transit Authority of Dallas, Texas (collectively, the "State") obtained a summary judgment against appellant Thomas Wilson for a portion of the sales tax liability of a corporation owned and controlled by Wilson, under section 171.255 of the Texas Tax Code. Wilson appeals, arguing that the State failed to assess him personally and file suit against him...
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