OPINION
HENDLEY, Judge.
Taxpayer appeals an order and decision of the Department which denied a protest of assessed gross receipts tax, interest and penalty on its sales of mobile homes. We affirm.
Taxpayer raises three issues on appeal: (1) the constitutionality of New Mexico's taxing scheme vis-a-vis mobile homes; (2) assuming the taxing scheme to be constitutional, whether it was proper to impose a penalty on Taxpayer for failure to timely pay...
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