Texas Court of Appeals, 3rd District (Austin) June 3, 2005, 03-04-00342-CV (First American Title Insurance Co. v. Strayhorn)

OPINION

DAVID PURYEAR, Justice.

First American Title Insurance Company and Old Republic National Title Insurance Company sell title insurance in Texas but are incorporated in other states. They are seeking to recover taxes they argue were unlawfully imposed upon them. Texas imposes a tax on the amount of premium collected from title insurance policies.