George R. v. Director of Revenue Divicsion Taxation

I dissent.

This case is a matter of first impression.

Taxpayer is the owner and operator of a real estate complex located in Santa Fe, New Mexico, one portion of which is registered with the Bureau as “King’s Rest Court.” The complex consists of:

(A) A motel area operated as “King’s Rest Court” that is “U”-shaped and numbered 1 through 21. This area has its own drive-in entrance and parking area. At the entrance of this area is a large sign “King’s Rest Court” which also lists “kitchenettes.” All gross receipts taxes were paid on receipts from this area.

(B) An apartment area owned and operated…