Texas Court of Appeals, 8th District (El Paso) January 26, 2005, 08-02-00511-CV (Tierra Sol Joint Venture v. City of El Paso)

OPINION

RICHARD BARAJAS, Chief Justice.

This is an appeal from a delinquent tax collection suit. For the reasons stated, we reverse and remand.

I.

SUMMARY OF THE EVIDENCE

Appellee, the City of El Paso, filed suit against Appellants, Tierra Sol Joint Venture (the “Joint Venture”) and Samuel and Company, Inc.