OPINION
SUTIN, Judge.
This is a gross receipts tax case directly appealed by Westland Corporation from the decision and order of the Commissioner of Revenue under Administrative Procedures Act, §§ 4-32-1 to 4-32-25, N.M.S.A. 1953 (Repl.Vol. 2, Supp. 1969), adopted by the legislature in 1969. This was pursuant to Westland's "Notice of Appeal" in the transcript on appeal. In its brief, Westland states that...
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