National Potash Co. v. Property Tax Division of the Taxation & Revenue Department

OPINION

HENDLEY, Judge.

National Potash Company (Taxpayer) appeals from a special order of the Director of the Property Tax Division (Director) affirming the Property Tax Division’s (Division) valuation of Taxpayer’s potash mine for the 1982 tax year. Taxpayer contends that NMSA 1978, Section 7-36-24 (Repl. Pamp.1983) violates N.M. Const, art. VIII, Section 1 by using production of the previous year as the value and that Section 7-36-24 creates an irrebuttable presumption of value in violation of the due process clause of the fourteenth amendment to the United States Constitution. These are…