ISSUES IN SUIT.
Tex. TAX Code § 112.152.
in effect(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.