American Automobile Ass'n v. Bureau of Revenue

OPINION

WOOD, Chief Judge.

The issue is whether taxpayer is entitled to the tax exemption appearing in § 72-16A-12.27, N.M.S.A.1953 (Repl.Vol. 10, pt. 2, Supp.1973). We held taxpayer was not a “nonprofit” organization in American Automobile Ass’n, Inc. v. Bureau of Rev., 86 N.M. 569, 525 P.2d 929 (Ct.App.1974). The New Mexico Supreme Court reversed and remanded “for a determination of whether [taxpayer] is a ‘business organization,’ and whether . . . the receipts involved are from ‘dues and registration fees.’ ” 87 N.M. 330, 533 P.2d 103, Supreme Court, decided March 21, 1975. The “business…