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TAX. & REV. DEPT. v. BIEN MUR IND. MARK.

No. 18130.

770 P.2d 873 (1989)

108 N.M. 228

TAXATION AND REVENUE DEPARTMENT, STATE OF NEW MEXICO, Petitioner, v. BIEN MUR INDIAN MARKET CENTER, INC., Respondent.

Supreme Court of New Mexico.

Rehearing Denied April 12, 1989.

Attorney(s) appearing for the Case

Frank D. Katz, Daniel Yohalem, Sp. Asst. Attys. Gen., Santa Fe, for petitioner.

Raymond G. Sanchez, Robert J. Desiderio, Albuquerque, for respondent.

OPINION

RANSOM, Justice.

We granted certiorari to determine whether principles of taxpayer nonculpability or estoppel against the state may affect the period of time in which the Taxation and Revenue Department (Department) may assess and collect unpaid gross receipts taxes on cigarette sales to non-Indians from Bien Mur Indian Market Center, Inc. (Bien Mur). Bien Mur is a federally licensed non-Indian corporation doing business on the Sandia Indian Pueblo...

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