Texas Attorney General Opinion: KP-0192 Page: 3 of 5
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Mr. Randall Rice - Page 3
Subsection 25.19(a) requires the chief appraiser to deliver notice to a property owner in four
(1) the appraised value of the property is greater than it was in the preceding
(2) the-appraised value of the property is greater than the value rendered by
the property owner;
(3) the property was not on the appraisal roll in the preceding year; or
(4) an exemption or partial exemption approved for the property for the
preceding year was canceled or reduced for the current year.
Id. 25.19(a). Except for these four unique circumstances, subsection (a) does not require a chief
appraiser to provide notice to a property owner when a reappraisal results in a decrease in property
value. However, subsection 25.19(g) provides:
By April 1 or as soon thereafter as practicable if the property is a
single-family residence that qualifies for [a homestead exemption],
or by May 1 or as soon thereafter as practicable in connection with
any other property, the chief appraiser shall deliver a written notice
to the owner of each property not included in a notice required to be
delivered under Subsection (a), if the property was reappraised in
the current tax year, if the ownership of the property changed during
the preceding year, or if the property owner or the agent of a
property owner authorized under Section 1.111 makes a written
request for the notice.
Id. 25.19(g) (emphasis added).5 The plain language of this provision requires the chief appraiser
to provide written notice to a property owner in any year that property is reappraised, and the
Legislature made no exception to this requirement for disaster reappraisals. See Abutahoun v. Dow
Chem. Co., 463 S.W.3d 42, 46 (Tex. 2015) ("We look to the plain meaning of the words in a statute
as an expression of legislative intent.").
Notice provided pursuant to subsection 25.19(g) initiates the formal process for protesting
the new appraised value. See TEX. TAX CODE 25.19(g)(3) (requiring the notice to include "a
detailed explanation of the time and procedure for protesting the value"). With that process comes
certain deadlines by which a taxpayer must protest the appraised value or risk waiving the right to
do so.6 Such deadlines may pose significant burdens for disaster victims still working toward
5"Tax year" is defined as "the calendar year." TEX. TAX CODE 1.04(13).
6in most cases, a property owner will "have until May 31 or 30 days from the date the appraisal district notice
is delivered - whichever date is later" to file a notice of protest with the appraisal review board. See
https://comptroller.texas.gov/taxes/property-tax/protests/index.php; see also TEX. TAX CODE 41.44(a).
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Texas. Attorney-General's Office. Texas Attorney General Opinion: KP-0192, text, April 23, 2018; (https://texashistory.unt.edu/ark:/67531/metapth1051242/m1/3/: accessed April 19, 2019), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu; crediting UNT Libraries Government Documents Department.