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JOHNSON & JOHNSON v. TAXATION DEPT.

No. 17279.

936 P.2d 872 (1997)

1997-NMCA-030

123 N.M. 190

JOHNSON & JOHNSON and Affiliated Subsidiaries, Appellant, v. TAXATION AND REVENUE DEPARTMENT OF THE STATE OF NEW MEXICO, Appellee.

Court of Appeals of New Mexico.

Certiorari Denied April 16, 1997.

Attorney(s) appearing for the Case

Curtis W. Schwartz, Timothy C. Holm, Modrall, Sperling, Roehl, Harris & Sisk, P.A. Santa Fe, Paul H. Frankel, Morrison & Foerster, LLP, New York City, for Appellant.

Tom Udall, Attorney General, Bruce J. Fort, Special Ass't Attorney General, Taxation and Revenue Department, Santa Fe, for Appellee.

OPINION

PICKARD, Judge.

1. Johnson & Johnson (Taxpayer) entered into a compromise tax settlement agreement with the Taxation and Revenue Department (Department). The settlement agreement purported to settle all of Taxpayer's tax liability for all periods before 1991. We address three issues today: (1) whether we have jurisdiction over this appeal; (2) whether the signed settlement agreement between Taxpayer and the Department is conclusive on...

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