Johnson & Johnson v. Taxation & Revenue Department

OPINION

PICKARD, Judge.

1.Johnson & Johnson (Taxpayer) entered into a compromise tax settlement agreement with the Taxation and Revenue Department (Department). The settlement agreement purported to settle all of Taxpayer’s tax liability for all periods before 1991. We address three issues today: (1) whether we have jurisdiction over this appeal; (2) whether the signed settlement agreement between Taxpayer and the Department is conclusive on the parties as to all matters expressed therein even though the agreement did not' receive attorney general approval as NMSA 1978, Section 7-l-20(A) (Repl.…