Petition for Writ of Mandamus - Filed - Supreme Court of Texas
Petition for Writ of Mandamus - Filed - Supreme Court of Texas
Petition for Writ of Mandamus - Filed - Supreme Court of Texas
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AFFIDAVIT OF DONALD DEERE<br />
1. My name is Donald Deere. I hold a Ph.D. in economics from the<br />
Massachusetts Institute <strong>of</strong> Technology. I served as an economics pr<strong>of</strong>essor at <strong>Texas</strong><br />
A&M University <strong>for</strong> more than 20 years, and have been engaged full-time as a consulting<br />
economist <strong>for</strong> six years.<br />
2. I am over the age <strong>of</strong> 18 years and am competent and not otherwise<br />
disqualified to make this affidavit. I am personally familiar with the matters stated<br />
herein, and to my personal knowledge, they are true and correct.<br />
3. I prepared the table attached hereto, entitled "Economic Analysis <strong>of</strong><br />
Comptroller Business Tax Advisory Committee Report" (the "Table"). The Table<br />
summarizes data taken exclusively from the BUSINESS TAX ADVISORY COMMITTEE<br />
REPORT TO THE 82ND LEGISLATURE, December 2010, prepared by the <strong>of</strong>fice <strong>of</strong> Susan<br />
Combs, <strong>Texas</strong> Comptroller <strong>of</strong> Public Accounts (the "Comptroller Report"). Each column<br />
in the Table is accurately described as follows:<br />
(a) "Business Tax Paid ($1000s)" displays the amount <strong>of</strong> <strong>Texas</strong> franchise tax<br />
paid by the referenced industry as taken from the Comptroller Report ("Business<br />
Tax Paid")<br />
(b) "Estimated Taxable Margin ($ Millions)" displays the estimated taxable<br />
margin derived by dividing Business Tax Paid by the tax rate (1% or 0.5%<br />
depending on the industry) generally applicable to the referenced industry<br />
("Taxable Margin").<br />
(c) "2008 GSP ($ Millions)" displays the Gross State Product <strong>for</strong> 2008 <strong>for</strong> the<br />
referenced industry, as taken from the Comptroller Report ("GSP").<br />
(d) "Tax Paid as % <strong>of</strong> GSP" displays the referenced industry's Tax Paid as a<br />
percentage <strong>of</strong> GSP.<br />
(e) "Estimated Taxable Margin as % <strong>of</strong> GSP" displays the referenced<br />
industry's estimated Taxable Margin as a percentage <strong>of</strong> GSP<br />
(f) "<strong>Texas</strong> Receipts ($ Millions)" displays the <strong>Texas</strong> receipts <strong>of</strong> the referenced<br />
industry, as taken from the Comptroller Report ("<strong>Texas</strong> Receipts").<br />
(g) "Tax Paid as % <strong>of</strong> <strong>Texas</strong> Receipts" displays the referenced industry's Tax<br />
Paid as a percentage <strong>of</strong> <strong>Texas</strong> Receipts.<br />
(h) "Est. Taxable Margin as % <strong>of</strong> <strong>Texas</strong> Receipts" displays the referenced<br />
industry's estimated Taxable Margin as a percentage <strong>of</strong> <strong>Texas</strong> Receipts.
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