W. Robert Brown v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas And Ken Paxton, Attorney General of the State of Texas ( 2015 )

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN JUDGMENT RENDERED DECEMBER 3, 2015 NO. 03-14-00492-CV W. Robert Brown, Appellant v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas; and Ken Paxton, Attorney General of the State of Texas, Appellees APPEAL FROM THE 250TH DISTRICT COURT OF TRAVIS COUNTY BEFORE JUSTICES PURYEAR, PEMBERTON, AND BOURLAND REVERSED AND REMANDED -- OPINION BY JUSTICE PURYEAR This is an appeal from the judgment signed by the trial court on July 7, 2014. Having reviewed the record and the parties’ arguments, the Court holds that there was reversible error in the portions of the trial court’s judgment regarding whether the statute of limitations bars the tax assessment at issue and whether the occasional-sales exemption applies. Therefore, the Court reverses the trial court’s summary judgment in favor of appellees and remands the case to the trial court for proceedings consistent with this opinion. Appellees shall pay all costs relating to this appeal, both in this Court and the court below.