of the Permanent University Fund (Sections 11, 11a, and 11b) and mandates the establishment of "a University of the first class" (Section 10) to be called The University of Texas, as well as "an Agricultural, and Mechanical department" (Section 13, today's Texas A&M University, which opened seven years prior); it also establishes Prairie View A&M University in Section 14. The University of Texas was originally created in the Constitution of 1858, and Texas A&M University was created from the Morrill Act. In 1915 and 1919, Constitutional Amendments were proposed to separate the two university systems, although both failed. Article 8: "Taxation and Revenue" Article 8 places various restrictions on the ability of the Legislature and local governments to impose taxes. Most of these restrictions concern local property taxes. Section 1-e prohibits statewide property taxes. This Section has been the subject of numerous school district financing lawsuits claiming that other Legislative restrictions on local property taxes have created a de facto statewide property tax; the Texas Supreme Court has at times ruled that the restrictions did in fact do so (and thus were unconstitutional) and at other times ruled that they did not. Texas has never had a personal income tax. In 2019, the constitution was amended to ban any future income tax, which has the effect of requiring a 2/3 majority of the legislature to vote to repeal the ban. Previously, the requirement to pass any future income tax was passage by a statewide referendum, which requires a simple majority vote of the legislature to add the question to a referendum. In May 2006 the Legislature replaced the existing franchise tax with a gross receipts tax. Article 9: "Counties" Article 9 provides rules for the creation of counties (now numbering 254) and for determining the location of county seats. It also includes several provisions regarding the creation of county-wide hospital districts in specified counties, as well as other miscellaneous provisions regarding airports and mental health. Article 10: "Railroads" Article 10 contains a single section declaring that railroads are considered "public highways" and railroad carriers "common carriers". Eight other sections were repealed in 1969. Article 11: "Municipal Corporations" Article 11 recognizes counties as legal political subunits of the State, grants certain powers to cities and counties, empowers the legislature to form school districts. Texas operates under Dustin's Rule: counties and special districts are not granted home rule privileges, while cities and