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ADVANCE SCHOOLS, INC. v. BUREAU OF REVENUE

No. 10728.

547 P.2d 562 (1976)

89 N.M. 79

ADVANCE SCHOOLS, INCORPORATED, Petitioner, v. BUREAU OF REVENUE, Respondent.

Supreme Court of New Mexico.

March 15, 1976.

Attorney(s) appearing for the Case

Ortega, Snead, Dixon & Hanna, Robert M. Dixon, Albuquerque, for petitioner.

Toney Anaya, Atty. Gen., Jan E. Unna, Asst. Atty. Gen., Bureau of Revenue, Santa Fe, for respondent.

OPINION

STEPHENSON, Justice.

The taxpayer, Advance Schools, Inc., protested an assessment of the New Mexico gross receipts tax, and after a formal hearing, the Commissioner of Revenue (Commissioner) upheld the assessment. An administrative appeal was taken to the Court of Appeals.1 The Court of Appeals affirmed the decision and order of the Commissioner. Advance Schools, Inc. v. Bureau of Revenue, N.M.,

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