Legal Opinion · Dissent
Advance Schools, Inc. v. Bureau of Revenue
New Mexico Court of Appeals
Decided December 30, 1975No. 1754Published
1DissentSutin, Judge
I dissent.
There are two questions for decision in this case.
(A) Is there substantial evidence to support the Commissioner’s Decision and Order?
(B) Was the Commissioner’s Decision and Order unlawful under the Constitution ?
(A) Substantial evidence does not support the Commissioner’s Decision and Order.
ASI, an Illinois corporation, is engaged in business in Illinois as a correspondence school.
We must clear the picture of ASI’s operations. ASI was not qualified to do business in New Mexico. It maintained two district offices here — one in Albuquerque which had one to three sales representatives,…
2Cases cited39 opinions
- Robbins v. Shelby County Taxing DistrictSupreme Court of the United States · 1887
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
- Western Live Stock v. Bureau of RevenueSupreme Court of the United States · 1938
- Miller Brothers Co. v. MarylandSupreme Court of the United States · 1954
- National Bellas Hess, Inc. v. Department of RevenueSupreme Court of the United States · 1967
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