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Texas — Christian v. Venefits, No. 05-17-01218, decided 11/27/18. The Texas Court of Appeals ruled a default judgment against a corporation whose privileges were forfeited for failure to file an annual franchise tax report could not serve as the basis to impose liability on the corporation’s former president under the section of Texas’ tax law holding officers liable for debts incurred after the failure to file a report or pay a tax.