Texas Court of Appeals Addresses Dealer's Heavy Equipment Inventory Taxation and Section 25.25 Appraisal Roll Corrections After EXLP Leasing

J-W Power Company, which leases natural-gas compressors to customers in oil-and-gas fields, sought to correct Henderson County's 2013-2016 ad valorem tax appraisals under Tax Code Section 25.25, arguing the equipment should be taxed only in Gregg County as dealer's heavy equipment inventory under the EXLP Leasing framework. The Tyler Court of Appeals affirmed summary judgment for the appraisal district, holding JWP failed to establish as a matter of law that the compressors were subjected to multiple appraisals or did not exist in the form or location described on the appraisal rolls.