Legal Opinion

MPC Ltd. v. New Mexico Taxation & Revenue Department

New Mexico Court of Appeals

Decided October 2, 2002No. 22,158PublishedCited by 7 opinions

1Opinion of the Court

OPINION

SUTIN, Judge.

{1} MPC, Ltd. d/b/a Manpower of New Mexico (Manpower) appeals the district court’s denial of a claim for refund of gross receipts tax assessed by the New Mexico Taxation and Revenue Department (the Department). Manpower asserted it was not liable for tax on its gross receipts (receipts) from clients to which it provided temporary staffing services. Employing statutory presumptions that receipts are taxable and the Department’s assessment was correct, the district court held the receipts are taxable as reimbursements of payroll-related expenditures.

{2} Manpower contends the…

2Cases cited11 opinions

  1. ITT Educational Services, Inc. v. Taxation & Revenue DepartmentNew Mexico Court of Appeals · 1998
  2. Stueber v. PickardNew Mexico Supreme Court · 1991
  3. Archuleta v. O'CheskeyNew Mexico Court of Appeals · 1972
  4. Wing Pawn Shop v. Taxation & Revenue DepartmentNew Mexico Court of Appeals · 1991
  5. Johnson v. Yates Petroleum Corp.New Mexico Court of Appeals · 1999

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3Cited by7 opinions

  1. N.M. Taxation & Revenue Dep't v. Casias TruckingNew Mexico Court of Appeals · 2014
  2. A&W Rests., Inc. v. Taxation & Revenue Dep't of N.M.New Mexico Court of Appeals · 2018
  3. New Mexico Taxation & Revenue Department v. Casias TruckingNew Mexico Court of Appeals · 2014
  4. Gemini Las Colinas, LLC v. N.M. Tax'n & Revenue Dep'tNew Mexico Court of Appeals · 2023
  5. Lopez v. Transitional Hospitals of N.M.New Mexico Court of Appeals · 2023

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