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STERLING TITLE CO. OF TAOS v. COMMISSIONER OF REV.

No. 1074.

511 P.2d 765 (1973)

85 N.M. 279

STERLING TITLE COMPANY OF TAOS (formerly Title Guaranty and Insurance Company), a New Mexico corporation, and Sterling Title Company (formerly Dona Ana Title Guaranty, Inc.), a New Mexico corporation, Protestants-Appellants, v. COMMISSIONER OF REVENUE of the State of New Mexico, Appellee.

Court of Appeals of New Mexico.

June 13, 1973.

Attorney(s) appearing for the Case

Sterling F. Black, Albuquerque, for protestants-appellants.

David L. Norvell, Atty. Gen., Susan P. Graber, Bureau of Revenue, Asst. Atty. Gen., Santa Fe, for appellee.

OPINION

WOOD, Chief Judge.

Dona Ana (Dona Ana Title and Abstract Company, a New Mexico Corporation) contracted with Title Guaranty (Title Guaranty and Insurance Company, a New Mexico Corporation). Under the contract, Title Guaranty purchased the tangible assets of Dona Ana. Sterling (Sterling Title Company of Taos) is the corporate successor to Title Guaranty. Dona Ana owed certain taxes. The Commissioner of Revenue made demand upon Sterling for the payment...

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