OPINION
HENDLEY, Judge.
Taxpayer is an Arizona Corporation, headquartered in Phoenix, Arizona, involved in road building activities. The work performed, which involves the instant penalty assessment, was done on the Navajo Reservation within the boundaries of New Mexico. For all practical purposes this was the first road job taxpayer had done in New Mexico.
On appeal taxpayer's sole issue is whether it is subject to a penalty assessment. Section...
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