New Mexico Enterprises, Inc. v. Bureau of Revenue

OPINION

HENDLEY, Judge.

Taxpayer was assessed certain taxes under the Gross Receipts and Compensating Tax Act, § 72-16A-1 et seq. N.M. S.A.1953 (Repl. Vol. 10, pt. 2, 1961, Supp. 1973), for the period of July 1, 1966 through June 30, 1971 and for the period of January 1, 1966 to July 1, 1966 under the Emergency School Tax Act, § 72-16-2 et seq. N.M.S.A.1953 (Repl. Vol. 10, pt. 2, 1961, Supp.1965). The assessment was upheld by Decision and Order of the Commissioner of Revenue on the basis of stipulated facts.

The material stipulated facts are as follows: Taxpayer “. . . was engaged in the…