OPINION
WOOD, Chief Judge.
The issue in this tax case is whether a sum of money equal to the amount paid to attorneys for title opinions is a gross receipt of the taxpayer (Title Services, Inc.). The Commissioner of Revenue assessed gross receipts tax, penalty and interest on such an amount; the taxpayer protested; its protest was denied. Taxpayer appeals directly to this Court. Section 72-13-39, N.M.S.A. 1953 (Repl.Vol. 10, pt. 2, Supp. 1973). We do not...
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