The answer to both subdivisions (A) snd (B) oi’ your first issue of the applicability Queatlon iurm upon the single of’ sub- section (c), ‘action 3, ?enate Bill 402, Acts heguler session, 46th :eglslcture, being i.I%lCle 7336, as wended, ~ernon*s Annotated Clvii ?;tatutes, to Independent school dlstrlots. This krtlole, as an ectlrety, allows a split-paymnt of taxes generally, the first hnlf to be p&id on or before ??ovexbcr 30th of a gfven ,tex year and the last halt on or before July lnt o: the following year, and pro- vides for a~ 2$ penalty on rhls last installment If not paid when due. It 1~ rurther provided that if taxes are not peid la thla mimer and althin this tine, then such tares will become del.inGuent if not paid prior to E‘ebruary 1st of the year succeeding the year when the assessment rolls are returned, and will carry certain gradu- cf from l$ to 2$ for the month ct February through ated penalties the wnth of July. The particular portion of the Artlole with whloh we cre conoerned here , Fubdf vision (0) , provides that when the tore- going split-payment plan of tax payments is adopted, dlsoounts shall be allowed for prompt payment es follows:

“(a) If one-half (l/2) of such ad velorem taxes have been paid on or before November thirtieth of the year in which the eeme are assessed, the discount8 herein pro- vided for shall be effeotlve ahd shall apply to the last half of the ad velorem taxes lf paid ninety (QO), sixty (60), and thirty (30) days, respeotively, prior to the rlret day of July, when the same beoone delinquent as here- in provided; but such discount shall not apply to the first half oT such tams If the same have bmen paid on or betore Moveabber thirtieth of the year in which suoh easesemant Is made.*

For aught that appears in the ioregolng provisions of Artlola 7336, aa mended, Vernon’s Annotated Civil Ftatutas, oonslder- ad in its entirety, the ao-aelled split-payment plan of tax payments to the taxes of independent school dlstriots and would be applicable Subaectlon (0) would be evelleble, beceuse the discount featurs loneuage of the statute 1s broad an4 general in scope so as to oomprehend all poll taxes and all ad velorem .taxes. But these statutory provisions mst be coneldered in aon- motion with those of Section 1, Senate Bill 402, .kota, Regular Ses- sion, 46th Leglalature, now Artlole 70576, Vernon’s hnnotated Civil statutes, allowing the oonstitutional dieoouut for proltpt payment of taxes due va~rlous polftioal subdIvisiona and taxing dlotrlcts if end when the the ftate, including Independent aohool districts, governing body oi such alatrlots and aubdlvlslons adopts aueh dls- Count feature, but further providing, that *in no event shall the *3 ssme apply to split-payment of taxes." This speolflo prohibition musti govern the general provisions of ~ubdlvlslon (0). hrtiols 7336, Vernon’6 &notated Civil Statutes, allowing the dfsoount on the last Installment when taxes are paid on the split-payment plan.

~4noe it is too plain for further disousalon that the latter pro- can htiv6 ~0 tippltcati0n 60 ina9p4na4d school amri0ts.ana ti~i0n ~0 aieO0m 44n be allowed tax44 of independent sohool .afstrimt, psla under the split-payment plan ) avon thou&h the govsrning b0ap suoh ina4ppenaent school aistriot ordsrs the allowanob OS suoh dlsoount Ecnerally.

But we do not man to hereby hold that lna49enaent eohool districts oannot elect, by proper order of its board or trusteas, to adopt the other provisions o? Xrt5.014 7336, Vernon@6 Annotated Civil Statutes, regarding ths payment or tax48. For a full ais0u4- sion oi this yuaetion, w4 enclosa herewith oopy of Opinion MO.

O-1352, dlreoted to Hon. L. h. Koodu, State Superintendent of Public Instruction,

Your eeoond inquiry relates to tha appltostion of Sub- diviSion IO), ~rtlols 7336, V4rnon1a Annotated Clvll Statuta8, to State and county ad valorem taxes. This Department, in opinion 130. O-1187 to Eonorabla Oeo. II. Sheppard, Couptrollsr of Pub110 Aooountts, held that, under the Statut,es dlsoussed in this opinion, the aisoount ror promgt payment will allowed on the last lnstall- msnt or state ad oaloram taxo4, paid on the ro-4alled~,,~pl.it-payment plau, but will not b4 d;ll@wsa on either lnstallasnt of oounty ad valomm tares when so,paid. This opinion furnlrhso a speolrlo amwor to your gu64tion, and WI accordingly enolosa a oopy thereof for your convenlenoe and information.

Yrustlne w4 have satiafaotorlly answered your inqulrlee, we are

Yours very truly ATTOm C-L OF TSXAS AP

ATTOB;lEY GW3,RAL OF TIEX,4~