Texas Court of Appeals, 14th District (Houston) September 4, 2003, 14-02-01282-CV (Andrews v. Aldine Independent School District)

OPINION ON REHEARING

SCOTT BRISTER, Chief Justice.

We withdraw our opinion of July 24, 2008, and issue this opinion on rehearing. Rawle Andrews died on July 12, 2001, leaving behind him substantial tax liabilities. Shortly thereafter, his son was appointed executor of his estate and a dependent administration was opened.