The First Court of Appeals has similarly stated, "If the property owner happens to state the same valuation opinion as the appraisal district representative . . . an agreement is reached." Bullseye PS III LP v. Harris Cnty. Appraisal Dist., 365 S.W.3d 427, 434-35 (Tex. App.—Houston [1st Dist.] 2011, pet. denied); see Hartman v. Harris Cnty. Appraisal Dist., 251 S.W.3d 595, 600 (Tex. App.—Houston [1st Dist.] 2007, pet. denied) ("When the [property owners'] agent and the appraiser each announced the same opinion as to the value of the property, they were in 'the act or fact of agreeing' and were expressing a 'harmony of opinion.'"). B
Town of Bartonville Plan. & Zoning Bd. of Adjustments v. Bartonville Water Supply Corp., 410 S.W.3d 23, 30 (Tex. App.—San Antonio 2013, pet. denied) (citation omitted); see also Harris County Appraisal Dist. v. Tex. Workforce Common, 519 S.W.3d 113, 130 (Tex. 2017) (recognizing that ARBs perform quasi-judicial functions).See, eg, Advanced Powder Sols., Inc v Harris County Appraisal Dist., 528 S W.3d 779, 788 (Tex. App.—Houston [14th Dist.] 2017, pet. granted, judgm’t vacated, remanded by agr.); Bullseye PS III LP v. Harris County Appraisal Dist, 365 S.W.3d 427, 435 (Tex. App.—Houston [1st Dist.] 2011, pet. denied); SondockvHarris County Appraisal Dist., 231 S.W.3d 65, 69 (Tex. App.—Houston [14th Dist.] 2007, no pet.); MHCB (USA) Leasing & Fin. Corp. v. Galveston Cent. Appraisal Dist. Rev. Bd., 249 S.W.3d 68, 83 (Tex. App.— Houston [1st Dist.] 2007, pet. denied).See Tex Tax Code § 41.01(b).
Sondock and its progeny rely on the ordinary meaning of "agreement," because the Property Tax Code does not define the term. Id. ; see alsoBullseye PS III LP v. Harris Cty. Appraisal Dist. , 365 S.W.3d 427, 432 (Tex. App.—Houston [1st Dist.] 2011, pet. denied). We note that in other contexts, the Property Tax Code requires agreements to be in writing and signed.
Appraisal Dist., 365 S.W.3d 427, 432 (Tex. App.-Houston [1st Dist.] 2011, pet. denied). IV. DISCUSSION
Bastrop Cent. Appraisal Dist. v. Acme Brick Co. , 428 S.W.3d 911, 917 (Tex. App.—Austin 2014, no pet.) (quoting Bullseye PS III LP v. Harris Cnty. Appraisal Dist. , 365 S.W.3d 427, 432 (Tex. App.—Houston [1st Dist.] 2011, pet. denied) ). Indeed, the Tax Code provides that "[t]he board may not review or reject an agreement between a property owner or the owner's agent and the chief appraiser under Section 1.111(e)." Tex. Tax Code § 41.01(b).
In the context of taxpayer challenges to Section 1.111(e) agreements, courts have held that the finality of those agreements renders irrelevant any subsequent determinations by the appraisal review board about property value. E.g., Bullseye PS III LP v. Harris Cnty. Appraisal Dist., 365 S.W.3d 427, 435 (Tex.App.-Houston [1st Dist.] 2011, pet. denied); Sondock, 231 S.W.3d at 69. The agreements become final without approval or adoption by the appraisal review board.