Texas Attorney General Opinion: WW-431 Page: 1 of 9
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TUn AoIE YITOR k;nE As.
O Al.' .TExAM
WIIAL WIiAON
AfPORNCY OmNE&ALMay 21.., 1958
Hon. Frank R. Nye, Jr.
rount rAttnrneyOpinion No. WW-431
WW%6A& LVy X kVVW v A1,
Starr County Re: Questions concerning the
Rio Grande City, Texas ad valorem taxability
against Sun Oil company
as processor of certain
gas designated as plarkt
Dear Mr, Nye: operator , .Sprtion..
You submit for the opinion of this. office tWo questions
presented in your letter of February 20, 1958. For a com-
prehensive statement of the problem presented we deem it
desirable to quote your opinion request in full, which is
as follows:
"There are a large number of oil and gas wells in
Starr County, Texas, in active production, an4 which
are subjected to ad valorem taxes by the State,
County, and various Independent School DistriQts.
Basically, in assessing their taxes, the County (in
behalf of itself and the State of Texas) and School
Districts treat each lease producing oil and gas as
a separate entity, so that the lessee is assessed
7/8 as a determinable fee estate, and the lessor,
or landowner, is assessed the usual 1/8 royalty as
a fee estate.
"Where oil alone (and no casinghead gas or other
liquid hydrocarbons) is produced evaluation poses
no problem. But where casinghead gas and liquids
from gas production are processed off the leases a
complication arises. Plants designed for this pur-
pose have been built; and it is in conjunction with
them that the officials of Starr County are in doubt
about whether all property subject to taxation is
being effectively reached.
"Specifically, the Sun Oil Company constructed a
plant in the San Isidro Community of Starr County
in 1949 which during -he year 1956 took the gas from
575 wells. That plant handled 22,904,654 MCF of
such gas during the calendar year of 1956, producing
therefrom 862,335 bbls, of liquids,
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Texas. Attorney-General's Office. Texas Attorney General Opinion: WW-431, text, May 21, 1958; (https://texashistory.unt.edu/ark:/67531/metapth267043/m1/1/: accessed July 16, 2024), University of North Texas Libraries, The Portal to Texas History, https://texashistory.unt.edu.; crediting UNT Libraries Government Documents Department.