OPINION
LOPEZ, Judge.
Pursuant to § 7-1-25, N.M.S.A. 1978 [formerly § 72-13-39, N.M.S.A. 1953 (Repl.Vol. 10, pt. 2, Supp. 1975)], Taxpayer-appellant appeals a Decision and Order of Bureau-appellee's Commissioner affirming the Bureau's assessment of corporate income taxes on the sale of Taxpayer's Wyoming coal leases. The Bureau determined the proceeds from the sale to be business income under § 7-4-2 A, N.M.S.A. 1978 [formerly § 72-15A...
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