OPINION
COWAN, Judge.
Westland Corporation appeals from a Decision and Order of the Commissioner of Revenue pursuant to § 72-13-39, N.M.S.A. 1953 (Repl.Vol. 10, pt. 2, 1971 Supp.).
We affirm.
This is a second appeal. The background factual situation is set out in the earlier appeal, Westland Corporation v. Commissioner of Revenue,
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