OPINION
HERNANDEZ, Judge.
Taxpayer owns and operates a motel-type complex in Santa Fe. The Taxation and Revenue Department (Department) assessed the Taxpayer $611.11 for gross receipts tax, penalty, and interest for the reporting period January 1974 to August 1976. This assessment was based on the Department's determination, following an audit, that the Taxpayer had improperly deducted receipts from eight rental units and amounts paid to a third party for...
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