OPINION
WATSON, Justice.
The Bureau of Revenue of the State of New Mexico brought suit against Dale J. Bellamah Corporation and Dale Bellamah Equipment Corporation to recover tax assessments due under the Emergency School Tax Act (§§ 72-16-1 through 72-16-47, N.M.S.A., 1953 Comp. [since repealed]) for the period from November 1, 1959 to December 15, 1964, on gross receipts from management and engineering services and from equipment rental. The...
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