Genesis Tax Loan Services, Inc. v. Kothmann, 339 S.W.3d 104

Kothmanns own vendors' liens on four parcels, each secured by a recorded deed of trust.
Genesis Tax Loan Services paid the taxes and claimed a tax lien transfer under Tex. Tax Code §32.06 by recording affidavits and copies after the originals were lost.
Original transfers were never recorded; Genesis attached verified photocopies with Genesis's president's affidavit claiming originals were lost.
Receipts issued by the tax collector shortly after transfers misidentified the owner as the Kothmanns and the tax collector had no seal on the transfer at the time.
The trial court admitted Genesis's copies over Kothmanns' objections; the court of appeals reversed, sustaining objections to the prima facie case and questioning enforceability under §32.06.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether copies recorded in lieu of originals satisfy §32.06(d).	Kothmanns contend copies cannot replace originals for enforceability.	Genesis contends verified copies are sufficient under Rule 1003-like principles and §32.06.	Yes; verified copies may be recorded and enforceable.
Whether the lack of a literal seal on the tax collector's certification voids the transfer.	Kothmanns argue absence of the seal defeats enforceability.	Genesis argues acknowledgment before a notary suffices.	Certification before a notary with the notary seal satisfies §32.06(d).
Whether the tax collector's failure to keep a record of all transfers bars enforceability.	Kothmanns claim lack of records undermines validity.	Genesis's transfer validity does not depend on the keeper’s records.	Record-keeping requirement is not a prerequisite to enforceability.
Whether the receipts’ timing/identification affect enforceability.	Kothmanns claim receipts' defects undermine transfer validity.	Receipts timing/content are irrelevant to enforceability.	Receipts are irrelevant to enforceability.
Whether the transfers complied with the overall statutory transfer requirements.	Kothmanns argue noncompliance with §32.06 subsections.	Genesis complied via verified copies and proper acknowledgments.	Transfers complied; liens enforceable.

Genesis Tax Loan Servs., Inc. v. Kothmann, 288 S.W.3d 503 (Tex.App.-Amarillo 2009) (holding verified copies can substitute originals for recording under §32.06)
Gorman v. Life Ins. Co. of N. Am., 811 S.W.2d 542 (Tex. 1991) (pleading and defense concepts; burden-shifting in lien disputes)