Justice Willett, delivered the opinion of the Court.

Many university campuses remain abuzz during the summer months, hosting various sports and other extracurricular camps for kids and teens. This property-tax dispute poses a question of first impression: whether a dormitory-like facility owned by a "higher education facility authority" forfeits its statutory property-tax exemption by providing summer housing to non-college students attending university-sponsored instructional programs.

The appraisal district contends the exemption imposes an exclusive use/benefit condition—meaning summer campers' use of otherwise vacant rooms defeats the property's tax-exempt status. We need not decide whether housing aspiring golfers, doctors, or cheerleaders violates statutory conditions—because there are no statutory conditions. The exemption is stated categorically, not conditionally. As worded, the exemption does not turn on whether a university hosts short, on-campus instructional programs. Although the housing authority may be subject to certain limitations affecting its ability to further the university's broad educational mission—terrain we do not reach today—the exemption statute is not one of them.

We reverse the court of appeals' judgment insofar as it denies tax-exempt status, and render judgment for Texas Student Housing Authority (TSHA).

I. BACKGROUND

The relevant facts are undisputed.

The town of Westlake created the non-profit TSHA in 1995.1 TSHA's bylaws provide that it "shall have all of the powers and authority granted to an authority under the Higher Education Authority Act."2 In 2002, TSHA acquired title to the Cambridge at College Station, a student-residential facility near the campuses of Texas A & M University (TAMU) and Blinn College.

TAMU is an "[i]nstitution of higher education,"3 and TAMU's board of regents4 is charged with (1) making "bylaws, rules, and regulations it deems necessary and proper for the government of the university system and its institutions, agencies, and services," and (2) "regulat[ing] the course of study and prescrib[ing] the course of discipline necessary to enforce the faithful discharge of the duties of the officers, faculty, and students."5 Like many universities, TAMU hosts various short-term extracurricular and enrichment programs for high school and elementary students. In the summers of 2005-2008, TSHA provided lodging at the Cambridge to participants in TAMU-sponsored summer camps.6 This housing was in addition to that provided to traditional university students who stayed at the Cambridge while attending regular summer school at either TAMU or Blinn College. TSHA's executive director testified that TSHA could have closed the Cambridge for the summer, but that TSHA would have been unable to keep the Cambridge open for summer school students without boosting the Cambridge's occupancy by housing the summer camp participants.

TAMU's 2005-2008 summer programs included the 4-H Roundup,7 the Joint Admission Medical Program,8 and various athletic camps. The athletic camps included tennis, volleyball, swim, and golf camps conducted directly by TAMU's Athletic Department, a hockey camp conducted by Hockey Ministries International Hockey Camp,9 and a cheerleading camp conducted by the UCA Cheer Camp.10 With the exception of participants in the Joint Admission Medical Program, most of the summer camp participants had not yet graduated high school. The parties stipulated that none of the programs conducted instructional activities at the Cambridge itself.

The various camps utilized different payment structures for TSHA's provision of housing. The Texas Agricultural Extension Service made arrangements with and paid fees directly to TAMU for the use of campus facilities for the 4-H Roundup. TSHA sent invoices directly to TAMU for the housing provided for the Joint Admission Medical Program and the athletic camps conducted directly by TAMU's Athletic Department. TSHA billed Hockey Ministries International and UCA Cheer Camp directly.

Citing the Cambridge's housing of these summer campers, the Brazos County Appraisal District (BCAD) voided TSHA's tax-exempt status for the years 2005-2008, and assessed millions of dollars in back taxes. TSHA unsuccessfully protested, then sought judicial review, arguing it was entitled to the exemption provided by the Education Code, and alternatively, the Tax Code.

The trial court affirmed BCAD's denial of exempt status, holding that TSHA forfeited the exemption once the Cambridge hosted "persons who were not students, faculty or staff members of an institution of higher learning." The trial court concluded that making the property available, even at TAMU's request, for short-term housing of participants in various university-sponsored summer programs violated conditions on which the exemption was premised.

TSHA appealed, and BCAD again contended that TSHA, by providing lodging to participants in summer camps bearing the imprimatur of TAMU sponsorship, could not satisfy the exemption's requirement that the property be "devoted exclusively to the use and benefit of the students, faculty, and staff members of an accredited institution of higher education."11 The court of appeals reversed the denial of tax-exempt status for 2005 but affirmed for years 2006-2008. The court of appeals distinguished 2005 on the basis that the only summer programs for which TSHA housed participants at the Cambridge in 2005—the 4-H Roundup and the Joint Admission Medical Program—had "definite and intimate relationships" with TAMU, "ones which are forged or supported by legislative mandate."12 The court of appeals also rejected TSHA's alternative contentions that the Cambridge was exempt under the Tax Code.

Both parties appealed to this Court.

II. DISCUSSION

This is our first opportunity to address the scope of the tax exemption provided by Education Code Chapter 53. Our inquiry is straightforward: Did TSHA establish its tax-exempt status as a matter of law? We answer yes, and accordingly do not reach TSHA's alternative argument that the property is also tax-exempt under the Tax Code.13

A. Standard of review

In tax-exemption cases, the claimant, here TSHA, bears the burden of "clearly showing" that it falls within the statutory exemption.14 Tax exemptions may not "be raised by implication, but must affirmatively appear, and all doubts are resolved in favor of taxing authority and against the claimant."15 Moreover, when construing any statute, including tax exemptions, the truest manifestation of what lawmakers intended is what they enacted.16 We adhere to this maxim "unless enforcing the plain language of the statute as written would produce absurd results."17 And we focus not on isolated words or phrases but on the statute as a cohesive, contextual whole.18

B. TSHA did not forfeit its exemption under Education Code Chapter 53 by housing summer program participants at the Cambridge.

At the time TSHA acquired the Cambridge, section 53.33 of the Education Code provided that an authority "by purchase, purchase contract, or lease, may construct, or may enlarge, extend, repair, renovate, or otherwise improve educational facilities or housing facilities. [The authority] may . . . provide by contract, lease, or otherwise for the operation and maintenance of the facilities."19 Similarly, the current version of section 53.33 provides that an authority "may acquire, own, hold title to, lease, or operate an educational facility or housing facility" if certain additional requirements are met.20 Both housing and educational facilities are defined in terms of their use:

In conjunction with the limited grant of authority in section 53.33, these definitions place specific restraints on an authority's ability to diversify its property holdings.22

Section 53.46, titled "Authority Exempt From Taxation," confers the exemption at issue here:

Although BCAD concedes that TSHA properly holds title to the Cambridge, BCAD argues the exemption is not absolute but conditional and hinges upon the authority's use of the property. According to BCAD, the Legislature was "probably sensitive to the notion that any use of a `housing facility' other than for students, faculty and staff, would give the authority an unfair competitive advantage over other properties that did not enjoy a tax exemption." As such, BCAD insists that, in order to qualify for the tax exemption, an authority must conclusively establish that its property is (1) "held for educational purposes only," and (2) "devoted exclusively to the use and benefit of the students, faculty, and staff members of an accredited institution of higher education."23 We reject BCAD's reading of the statute as conditional.

Both the title and text of section 53.46 declare rather emphatically that the authority is exempt from taxation. That is, the language seems focused on who the property owner is, not on how the property is used. The provision states a presumption (about how the property is held and used) then an unconditional proclamation (the property is tax-exempt). The introductory clause isn't worded as a condition—if the property is so held and used, then it's exempt. The exemption does not speak to property being used "nonexclusively" or impose consequences for such use.24 Rather, the statute seems to state in absolute terms that the property is, in all events, exempt.

The Legislature is well acquainted with how to condition tax exemptions on specific criteria or circumstances. The Tax Code includes numerous such exemptions, and their syntax bears no resemblance to that used in section 53.46:

Under these statutes—and numerous other examples28—"if" the entity or person fails to meet the stated conditions, then the property is not entitled to the exemption.

By contrast, the exemption in today's case is more akin to exemption statutes that use unconditional language, such that the property is exempt "because" its use is consistent with the limited powers of the identified type of entity:

The gist of BCAD's proposed construction—that no non-university persons or entities may ever use the property or benefit from it—finds no home in the exemption's language. BCAD's conditional reading is foreclosed by the statute's unconditional text.

Today's decision does not mean TSHA can use its property for any purpose it chooses. "Agencies may only exercise those powers granted by statute, together with those necessarily implied from the statutory authority conferred or duties imposed."33 An authority thus has no power to acquire, hold, or use property beyond its statutory authorization.34 If an injured party with standing brings and proves an action seeking to confine TSHA within its statutory constraints—and BCAD sought no such relief in this case—courts may intervene to provide an appropriate remedy, such as an injunction to prevent TSHA from continuing to exceed its limited statutory authority.35 Even if TSHA has governmental immunity—an issue we do not decide here36—governmental immunity would not protect its officials from suits to prevent ultra vires actions and obtain prospective relief.37

The denial of a tax exemption might be an appropriate additional remedy against an authority that commits its property to unauthorized or prohibited uses, de minimus or otherwise,38 but that is a policy judgment for the Legislature, which has provided no such remedy here. Instead, the Legislature has unconditionally granted TSHA a tax exemption and presumed that TSHA will use the property only for authorized purposes. In short, we need not decide whether TSHA's property meets the exemption's "conditions" because the exemption is not conditional.

Section 53.46 exempts property owned by a properly constituted higher education facility authority, and it does so unequivocally. Because BCAD does not dispute TSHA's assertion that TSHA is such an authority, the Cambridge "is exempt from taxation of every character."39

III. CONCLUSION

Rules of construction require us to resolve ambiguous language in favor of the taxing entity,40 but BCAD has not identified any language susceptible to the strained meaning it ascribes. We reject BCAD's view that TSHA forfeited its tax-exempt status under Education Code section 53.46 by housing non-college students attending TAMU-sponsored summer camps. As worded, the statute imposes no conditions but rather declares the property-tax exemption in absolute terms. The Legislature is adept at qualifying its tax exemptions, and if it wishes to disqualify properties that facilitate university-backed extracurricular programs, it can amend the statute.

We reverse the court of appeals' judgment insofar as it denies tax-exempt status for the Cambridge for any of the years at issue, and render judgment for TSHA.