The addition of section 41.411, however, provided taxpayers with the due process protections that had previously been lacking under the previous statutory scheme. Id. The purpose of section 41.411 is to determine whether a property owner failed to receive notice of a tax assessment, thereby depriving it of the right to be heard at the administrative level. See C.I.T. Leasing Corp., 115 S.W.3d at 266; General Elec. Corp., 819 S.W.2d at 919. Assuming without deciding that the Taxing Authorities sent the Taxpayers defective notice, the tax code that not scheduling a protest hearing was unconstitutional, after property owners had paid their taxes “under protest” and timely filed for a protest hearing); Garza v. Block Distrib. Co., 696 S.W.2d 259, 262 (Tex.App.-San Antonio 1985, no writ) (<HOLDING>). In Fisher, the El Paso Court of Appeals found
holding that an essential component of procedural fairness is an opportunity to be heard holding that the court did not have jurisdiction to consider an argument not presented to the board in a motion for reconsideration holding that the  district court did not give the plaintiffs an adequate opportunity to be heard where it failed to conduct an in limine hearing and denied oral argument on the evidentiary issues holding that an appraisal board did not acquire jurisdiction to consider an increase in the appraised value of the subject property when statute before the enactment of section 41411 did not require notice and an opportunity to be heard holding that absent exigent circumstances the due process clause requires the government to afford notice and a meaningful opportunity to be heard before seizing real property subject to civil forfeiture