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COMBS v. CHAPAL ZENRAY, INC.

No. 03-10-00646-CV.

357 S.W.3d 751 (2011)

Susan COMBS, Comptroller of Public Accounts of the State of Texas, and Greg Abbott, Attorney General of the State of Texas, Appellant, v. CHAPAL ZENRAY, INC., Appellee.

Court of Appeals of Texas, Austin.

Rehearing Overruled January 25, 2012.

Attorney(s) appearing for the Case

Dennis M. McKinney , Assistant Attorney General, Financial & Taxation Litigation Division, Austin, TX, for Appellant.

Joe T. Sanders II , Curtis J. Osterloh , Mark W. Eidman , Scott Douglass & McConnico LLP, Austin, TX, for Appellees.

Before Chief Justice JONES, Justices HENSON and GOODWIN.

OPINION

J. WOODFIN JONES, Chief Justice.

Appellee Chapal Zenray, Inc. ("Chapal") sued appellants Susan Combs, Comptroller of Public Accounts of the State of Texas, and Greg Abbott, Attorney General of the State of Texas (collectively, "the State"), seeking a refund of use taxes assessed on certain materials that were purchased from out-of-state sellers, were temporarily affixed to jewelry while in Texas, and were subsequently used by Chapal's out...

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