OPINION
HERNANDEZ, Judge.
Taxpayer, Eastern Navajo Industries, appeals pursuant to § 72-13-39, N.M.S.A. 1953 (Repl. Vol. 10, Supp. 1975), a Decision and Order of the Commissioner of the Bureau of Revenue assessing gross receipts to this taxpayer.
The fundamental issue in this appeal is whether incorporation by the taxpayer under our Business Corporation Act, Sections 51-24-1 to 51-31-11, N.M.S.A. 1953 (Repl. Vol. 8, pt. 1, Supp. 1975) will preclude...
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