An international tax consulting law firm prevailed on appeal against a state comptroller's argument it had no right to sue over an assignment of right to a tax refund, only to be told the refund was worthless.

In a case where sophisticated parties on both sides ended the day with some egg on their face, the Third District Court of Appeals dismantled every argument put forth by Texas Comptroller Glenn Hegar on standing, and informed the tax law firm it had misread reportable gains instructions—the basis of its claim on a $2.75 million right to refund it purchased from Hibernia Energy, an oil and gas exploration company.