OPINION
SUTIN, Judge.
Taxpayer appeals a decision of the Commissioner which imposed a gross receipts tax on the sale of mobile homes.
The facts were stipulated. Taxpayer is engaged in the business of selling mobile homes to people throughout the state. It maintains an inventory of mobile homes from which sales are made.
Section 72-16A-12.10, N.M.S.A. 1953 (Repl. Vol. 10, pt. 2, 1973 Supp.) of the Gross Receipts and Compensating Tax Act reads...
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