Westland Corporation v. Commissioner of Revenue

OPINION

COWAN, Judge.

Westland Corporation appeals from a Decision and Order of the Commissioner of Revenue pursuant to § 72-13-39, N.M. S.A.1953 (Repl.Vol. 10, pt. 2, 1971 Supp.).

We affirm.

This is a second appeal. The background factual situation is set out in the earlier appeal, Westland Corporation v. Commissioner of Revenue, 83 N.M. 29, 487 P.2d 1099 (Ct.App.1971). This court there determined that Westland was engaged in business, furnishing services to three other corporations with the latter paying to West-land funds in an amount calculated to cover Westland’s operations on their behalf.…