The opinion
ON MOTION FOR REHEARING
In his motion for rehearing Carr argues that Tex. Tax Code Ann. § 43.01 (Vernon 1982) authorized the taxing units to attack the action of the Appraisal Review Board in reducing The Breakers appraisal. We cannot agree that Section 43.-01 would apply to this situation. It provides that:
A taxing unit may sue the appraisal district that appraises property for the unit to compel the appraisal district to comply with the provisions of this title, rules of the State Property Tax Board, or other applicable law.
We believe the section applies to actions for declaratory or injunctive relief with respect to policies and operating procedures. It cannot refer to a suit to challenge the appraisal of a single taxpayer’s property, since that is expressly prohibited by Tex. Tax Code Ann. § 41.03 (Vernon 1982).
The motion for rehearing is overruled.