OPINION
HENDLEY, Judge.
Taxpayer was assessed certain taxes under the Gross Receipts and Compensating Tax Act, § 72-16A-1 et seq. N.M.S.A. 1953 (Repl. Vol. 10, pt. 2, 1961, Supp. 1973), for the period of July 1, 1966 through June 30, 1971 and for the period of January 1, 1966 to July 1, 1966 under the Emergency School Tax Act, § 72-16-2 et seq. N.M.S.A. 1953 (Repl. Vol. 10, pt. 2, 1961, Supp. 1965). The assessment was upheld by Decision and Order...
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