OPINION
OMAN, Judge.
This appeal was taken by appellant taxpayer from a written order of appellee Commissioner of Revenue, pursuant to § 16-7-8(F), N.M.S.A. 1953 (Supp. 1969), and § 72-13-39, N.M.S.A. 1953 (Repl. 10, pt. 2, Supp. 1969). The matter is before us on a stipulation of facts, and the portions of this stipulation essential to a determination of the issues presented under the points relied upon...
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