OPINION
LOPEZ, Judge.
This case involves an Illinois-based correspondence school which sells courses in New Mexico. The school contends that it should not be subject to New Mexico's Gross Receipts Tax. Sections 72-16A-3 and 72-16A-4, N.M.S.A. 1953 (Repl.Vol. 10, pt. 2, Supp. 1973). The Commissioner of Revenue found contrary to the taxpayer's position and it is from his decision that this appeal is taken. We affirm...
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