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  5. 931 P.2d 739 (1995)
 

CONOCO, INC. v. TAXATION & REVENUE DEPT.

No. 15372.

931 P.2d 739 (1995)

122 N.M. 745

1997-NMCA-4

CONOCO, INC., Plaintiff-Appellant, v. STATE of New Mexico TAXATION AND REVENUE DEPARTMENT, Defendant-Appellee.

Court of Appeals of New Mexico.

Certiorari Granted June 14, 1995.

Attorney(s) appearing for the Case

Curtis W. Schwartz and Timothy C. Holm, Modrall, Sperling, Roehl, Harris & Sisk, P.A., Santa Fe, for plaintiff-appellant.

Tom Udall, Atty. Gen. and Bruce J. Fort, Sp. Asst. Atty. Gen., Santa Fe, for defendant-appellee.

OPINION

APODACA, Chief Judge.

The issues in this appeal involve the New Mexico Taxation and Revenue Department's (the Department) denial of Conoco, Inc.'s (the taxpayer) refund claims for certain tax years and the Department's imposition of an assessment for the tax year 1991.

The taxpayer sought a refund of corporate income taxes paid to the State of New Mexico for the tax years 1988, 1989, and 1990, based on what its tax liability would...

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