Hoffman v. STATE, TAXATION & REV. DEPT.

OPINION

FLORES, Judge.

This ease involves, first, a challenge to a tax sale in which the delinquent taxpayer contends the State failed to comply with either statutory or constitutional due process requirements prior to the tax sale, and second, the effect the statute of limitations has on that challenge. See NMSA 1978, §§ 7-38-66 & -70 (Repl.1986). Although the trial court order cites to the 1990 Replacement Pamphlet, and the parties do not contest this point on appeal, we apply the provisions in the 1986 Replacement Pamphlet as the relevant law because the tax sale took place in November 1988.…