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County of Burleson et al. v. General Electric Credit Corp., 831 S.W.2d 54 (Tex.App.- <br />Houston [14th Dist.], 1992 writ den.): <br />Contrary to the way the facts are reported in the case, the taxing jurisdiction seized a <br />manufactured home which had a given serial number on it. The taxing jurisdiction applied to <br />the Texas Department of Licensing and Regulation for information regarding the ownership <br />and lienholders on the home of that serial number. No record with the Texas Department <br />of Licensing and Regulation was found. Later, after the tax sale, GECC appeared claiming <br />a lien on the manufactured home. It demonstrated to the trial court that the serial number of <br />the manufactured home was not what it had appeared to be, but a different number under <br />which GECC held a lien. The appellate court affirmed the decision of the trial court in favor <br />of GECC. <br />Civil Docket No. 92-009-5, In re Texas Draughon Institute, Inc.; Pine Tree Inde- <br />pendent School District v. Texas National Bank, Western District of Louisiana 1993: <br />This case is factually and legally nearly identical to the Boerne Hills Leasing case. The <br />bankruptcy court in Louisiana held for the secured lendor, Texas National Bank, distributing <br />all proceeds of the sale of personal property to it as opposed to a taxing jurisdiction. <br />Taxing jurisdiction appealed and won a procedural reversal at the district court. On remand <br />to the bankruptcy court, the taxing jurisdictions prevailed on the theory that 11 U.S.C. <br />§ 546 allows for post-bankruptcy petition perfection of the personal property tax lien via <br />the filing of a claim in bankruptcy. Texas National Bank appealed, but the decision was <br />affirmed by the district court. The case was settled prior to reaching the Fifth Circuit <br />Court of Appeals, with substantially all of the taxes being paid. <br />No. SA-92-CA-698, In re W.H. Mangum, Inc.; County of Comal et al. v. W.H. <br />Mangum, Inc. et al., United States District Court for the Western District of Texas <br />1994: <br />The bankruptcy court disallowed the taxing jurisdiction's claim for § 33.07 fees and interest <br />on administrative expenses. The court also disallowed taxes for the year of filing as an <br />administrative expense. Following the bankruptcy court decision in the Boerne Hills case, the <br />court also disallowed all pre-petition tax claims on personal property as being inferior to <br />commercial vendors' liens. The district court reversed the bankruptcy court on all points ruling <br />for the taxing jurisdiction. <br />No. 04-93-00279-CV, Stahmann Sales Company v. County of Guadalupe et al., 4th <br />Judicial District Court of Appeal-San Antonio, February 23, 1994 (writ den.): <br />This case resulted from a tax judgment for personal property taxes on a recreational vehicle <br />retailer. The defendant, on appeal, contended that the entire Texas ad valorem tax scheme <br />on personal property was unconstitutional, that CED taxes were unconstitutional, that the tax <br />McCreary, Veselka, Bragg & Allen <br />38 <br />