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BRIM HEALTHCARE v. STATE, TAX. & REV. DEPT.

No. 15658.

896 P.2d 498 (1995)

119 N.M. 818

BRIM HEALTHCARE, INC., Petitioner-Appellant, v. STATE of New Mexico, TAXATION AND REVENUE DEPARTMENT, Respondent-Appellee.

Court of Appeals of New Mexico.

May 1, 1995.

Attorney(s) appearing for the Case

Judith D. Schrandt, Sheehan, Sheehan & Stelzner, P.A., Donald E. Swaim, Albuquerque, for petitioner-appellant.

Tom Udall, Atty. Gen., Javier Lopez, Sp. Asst. Atty. Gen., Taxation and Revenue Dept., Santa Fe, for respondent-appellee.

OPINION

BLACK, Judge.

Brim Healthcare, Inc. (Brim), a corporation headquartered in Oregon, contracted to provide management services to two hospitals in northern New Mexico. Brim's services consisted of a management consultant function and a personnel staffing function.

In 1991, the New Mexico Department of Taxation and Revenue (the Department) performed an audit of Brim. As a result of that audit, the Department mailed Brim an assessment...

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