J-W Power Company v. Duval County Appraisal District, 04-21-00172-CV

J‑W Power owns compressor packages leased in the oil & gas industry and stores dealer heavy equipment inventory at a Jim Wells County yard and office; some compressors were leased for use in Duval County during 2013–2016.
Duval County Appraisal District placed certain compressors on its 2013–2016 appraisal rolls as business personal property; J‑W did not report those specific units to Jim Wells County for those years.
J‑W filed §25.25 correction motions with the Duval ARB (alleging multiple appraisals and inclusion of property not existing in the described form/location); ARB denied relief and J‑W sued for damages and other relief.
Texas Supreme Court precedent (EXLP Leasing) holds dealer heavy equipment inventory’s taxable situs is where the dealer maintains inventory and recognized the statutory prepayment/reporting scheme in §§23.1241–23.1242.
At summary judgment, the trial court granted Duval CAD’s motion and denied J‑W’s; the court concluded J‑W had not shown multiple appraisals because the Jim Wells CAD had not appraised the specific Duval units, and §25.25(c)(3) could not be used to relitigate taxable situs/classification.
The Fourth Court of Appeals affirmed: J‑W could seek relief under §25.25 in theory, but failed as a matter of law to prove entitlement to correction on the asserted grounds for 2013–2016.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §25.25(c)(2) authorizes correction for "multiple appraisals" when dealer inventory should be taxed in the dealer's yard county	J‑W: Duval appraised compressors that were part of Jim Wells dealer inventory, so units were doubly appraised	Duval: §25.25 cannot be used to change situs; and Jim Wells did not appraise those specific units because J‑W did not report them	Court: J‑W may seek §25.25 relief facially, but summary judgment for Duval proper—no double appraisal shown because Jim Wells had not included those units on its rolls
Whether §25.25(c)(3) allows correction by reclassifying tangible personal property in Duval as dealer inventory located in Jim Wells (i.e., challenging situs/form)	J‑W: Compressors are inventory (not mere tangible personal property) of Jim Wells yard and thus do not exist in inventory form in Duval	Duval: §25.25(c)(3) addresses physical nonexistence at the roll location, not disputes over taxable situs or classification	Court: §25.25(c)(3) inapplicable—compressors physically existed in Duval as described, so the provision cannot be used to relitigate situs/classification; summary judgment for Duval affirmed

EXLP Leasing, LLC v. Galveston Cent. Appraisal Dist., 554 S.W.3d 572 (Tex. 2018) (establishes that dealer heavy‑equipment inventory taxable situs is the dealer’s inventory location and explains §§23.1241–23.1242 prepayment/reporting scheme)
Willacy Cty. Appraisal Dist. v. Sebastian Cotton & Grain, Ltd., 555 S.W.3d 29 (Tex. 2018) (describes two direct avenues to change appraisal rolls: Chapter 41 protest and §25.25 correction)
Bosque Disposal Sys., LLC v. Parker Cty. Appraisal Dist., 555 S.W.3d 92 (Tex. 2018) (requires evidence of what property was included in each appraisal account to prove double taxation)
SPX Corp. v. Altinger, 614 S.W.3d 362 (Tex. App.—Houston [14th Dist.] 2020) ("location" in §25.25(c)(3) means physical location, not taxable situs)
Harris Cty. Appraisal Dist. v. Texas Gas Transmission Corp., 105 S.W.3d 88 (Tex. App.—Houston [1st Dist.] 2003) (interprets §25.25(c)(3) to address non‑existent property at the appraisal roll location)
Curtis C. Gunn, Inc. v. Bexar Cty. Appraisal Dist., 71 S.W.3d 425 (Tex. App.—San Antonio 2002) (defines "form" for §25.25(c)(3) as a physical description of the property)
Titanium Metals Corp. v. Dall. Cty. Appraisal Dist., 3 S.W.3d 63 (Tex. App.—Dallas 1999) (same—§25.25(c)(3) does not permit value or situs challenges)