The opinion
SUPPLEMENTAL OPINION ON SECOND PETITION FOR REHEARING
On Second Petition for Rehearing, Board of Equalization of Seminole County, argues that this Court held in our original opinion that “Gathering Systems” were, or may be exempt from ad valorem taxes. The effect of this argument is that we have extended tax exemptions to properties that have heretofore been subject to ad valorem taxes.
The issue as to what did or did not constitute a “Gathering System” was not before this Court, and by our opinion we did not intend to, nor did we, extend an exemption to “Gathering Systems” that were not heretofore exempt. In other words, this Court did not change or modify our previous holdings and the same statutory test exists now and that is whether the property is actually necessary and being used and in use in the production of oil, etc.