Ramah Navajo School Board, Inc. v. New Mexico Taxation & Revenue Department

OPINION

HARTZ, Judge.

{1} New areas of the law generate as much controversy, complexity, and confusion as the scope of a state’s power to impose taxes that impact Native Americans. Although the United States Supreme Court has written repeatedly on the subject — indeed, one of the leading cases involves the very parties before us in this case — no case decided by that Court is factually on all fours with this case, and it is difficult to determine which factual distinctions are of legal consequence.

{2} Ramah Navajo School Board, Inc. (the Board) is a Navajo tribal governmental entity which…