MEMORANDUM OPINION
DAVID PURYEAR, Justice.
Southwest Royalties, Inc. (Southwest), filed a refund claim with the Comptroller of Public Accounts of the State of Texas (Comptroller) for taxes that it paid from January 1, 1997, through April 30, 2001. See Tex. Tax Code § 111.104 (setting out requirements for tax-refund claim)....
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