Central Appraisal Dist. v. Lall
In Central Appraisal Dist. v. Lall, 924 S.W.2d 686, 690 (Tex. 1996), the supreme court, in upholding the constitutionality of a prior version of Texas Tax Code section 42.08(b) in response to an open courts challenge, specifically noted that requiring a taxpayer to pay the amount he conceded was due prior to appealing a taxing authority decision is a constitutional practice tracking the common law rule.
Thus, when the amount the taxpayer concedes is due is zero, requiring the taxpayer to pay something more might have constitutional implications under the open courts provision. id.