OPINION
DICKENSON, Justice.
Otis T. Hawkins is a property owner who appealed an order of the Van Zandt County Appraisal Review Board by suing it and the Van Zandt County Appraisal District pursuant to Tex.Prop.Tax Code Ann. § 42.01 (Vernon Supp.1992) concerning the taxes due for calendar years 1989 and 1990. Hawkins argues that the "winter protection structures"
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