(a) The only issues that may be raised in a suit under this subchapter are, as applicable, the:
(1) grounds of error contained in the motion for rehearing; or
(2) material facts and legal bases contained in the notice of intent filed under Section 111.0091(a) or 111.106(a).
(b) The suit applies only to a tax liability period considered in the comptroller's decision or covered by the notice of intent filed under Section 111.0091 or 111.106, as applicable.
Official text of the Texas Tax Code as published by the Texas Legislative Council.