He have your request for a opinion whioh reads as follows: "The question ha8 bsm raised by the tax oolleoto- 9 Au&* County as to whether or motr Seaate Bill No. 130, Aots ofthe Rggulu Session of ths 48th Legislature releases to a11 nmnberS of the armed forum of the United States of Amer$oa aad their auziliiries aad all mmlzars of the armed foroes ia reserve in the United State!+ of Awrioa Pnd their auxiliaries in World Har No. 2 all ixterest exd penalties aooruiag subequeat to their eatry into such servioe on the mad districts and oomon school distriots in Austia county.

"We have a oopy of youFopiait% addressed to Honorable~George Ho Sheppard, Cwptroller of PubliO Accounts, Austin, Tens, %y George P. Blaokbur*, your assistnat; and approved July 31, 1943 %y Grover Sellero, first assistant attorney general, mtd in the last paragraph of such opinion, you state that the aot applies to the interesf. and penalties of Stata pad oounty ad valormu -a taxes.

"Please advise me if *he aot also oovl)r~~ road distriot8 and oomoa school districta aa hereilaa$mo mqussted."

Although you do not speoifg what ohuaoter of *axe8 the noapayrwnt of which give rise to the wilateres.b aad pelultieo" about which you inqure, we assume you have refermoe to ad valorsa'tiaxe8 due road diatriota aad oommoa s&o01 dietriots. Thi8 opiaion aa written is boned upoathat assump- tion.

In our opinion IZo. O-6463, addrsssed to Honorable George H. Sheppard, Comptoller of Publio Aooouits,no held that Senate Bill lb. 130, 48th Legislature, me written ir lamguage 80 plaia aad uaambiguous that its meaning was so clear and obvious that Ohs law would be applied ad anforoed aa written, there bsilg tie room for ooastruotio~ of Its mmnfrg, and we oited aumrous authorfties.

Hon. Vi. D. Bryan, Page 2 10-5651)

In Opinion Roe. 5463 we *aid, in part8 'The method of the Act’s operation is to release to the above danmd persons said interest and penalties. The interest and-lies referred to ar6 plainly described in the Act as *all interest and penalties aooruing sutieQuent tot~heir entry into auoh servioe ON STATEi AND COUNTY AD VALORRM Tutes on property listed on the tax rolls of any county in the name of such me&era of the Armed Foroes or their auxiliaries or the drmsd Foroes Resellre or their auxiliaries prior to the time they joined such &mad Foroes or auxiliaries.'"

Refersmoe to the provisiosls of said Senate Bill 130 discloses that the Ri.11 does not deal with, mar in axy way attempt to deal with, the penalties and interest ahioh might aoorue by reason of nonpayment of any road distriot or oommon sohool district ad Valorem taxesf The Bill legislates with regard to the penalties and interest aooruiag by mason of the nonpayment of "State and county advaloren taxes. . . .*

The terms "State ad valoran taxes," "county ad valorem taxes,' "road district ad valorem taxes," and "camnon sohool ad valorem taxes" are terms of different signifioation and have long so been used in the Legislative emaot- meats of Texas* They are not synomymoua.

You we therefore advised that the provisions of Senate Bill lb. 130, 48th Legislature, do not operate to release to the medmrs of the Anned Forces of the United States and their a~iliaries, nor the members of the Amned Forces Reserve and their auxiliaries, any interest and penalties which might aocrua against them by reason of the nonpayment by them of any ad valorem tax- es due road distriots and cormnon sohool distriots in AustimCounty.

Yours berg truly ATTCRREYGIRJRRALOFTERIAS By /8/Geoo PO Blackburn George P* Rlaokbura As si stant GPBxAWregr

APPRGVgD OCT 14, 1943 Approved Opinion CmwxLttee /s/Gerald C. ?Jann ATTOF!XNY GNNERNA OF TEXAS VA= cH4IRNAN