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GEMINI LAS COLINAS v. TAXATION & REVENUE

No. A-1-CA-38672.

531 P.3d 622 (2023)

2023-NMCA-039

GEMINI LAS COLINAS, LLC, Protestant-Appellant, v. NEW MEXICO TAXATION & REVENUE DEPARTMENT, Respondent-Appellee, In the Matter of the Protest To Assessment Issued Under Letter ID NO. L0294038832.

Court of Appeals of New Mexico.

Filing Date: March 13, 2023.

Attorney(s) appearing for the Case

Betzer, Roybal & Eisenberg, LLC, Benjamin C. Roybal , Albuquerque, NM, Rodey, Dickason, Sloan, Akin & Robb, P.A., Edward Ricco , Albuquerque, NM, for Appellant.

Raúl Torrez , Attorney General, David E. Mittle , Special Assistant Attorney General, Santa Fe, NM, for Appellee.

OPINION

{1} This appeal arises from an unsuccessful administrative tax protest brought by Gemini Las Colinas, LLC (Taxpayer) against the New Mexico Department of Taxation and Revenue (Department). Taxpayer challenges the denial of its protest, arguing that the administrative hearing officer (AHO) (1) applied the...

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