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ITT v. TAXATION AND REVENUE DEPT.

No. 18137.

959 P.2d 969 (1998)

125 N.M. 244

1998-NMCA-078

ITT EDUCATIONAL SERVICES, INC., Petitioner-Appellant, v. TAXATION AND REVENUE DEPARTMENT OF the STATE of NEW MEXICO, Respondent-Appellee.

Court of Appeals of New Mexico.

April 27, 1998.

Attorney(s) appearing for the Case

Curtis W. Schwartz, Timothy R. Van Valen, Modrall, Sperling, Roehl, Harris & Sisk, P.A., Santa Fe, for Petitioner-Appellant.

Tom Udall, Attorney General, Frank D. Katz, Special Ass't Attorney General, NM Taxation & Revenue Department, Santa Fe, for Respondent-Appellee.

OPINION

ALARID, Judge.

{1} ITT Educational Services, Inc. (ITT) appeals the Decision and Order of the New Mexico Taxation and Revenue Department (Department). ITT appeals the Department's assessment of gross receipts tax based on the educational services that ITT provides within the State. ITT asserts that its curriculum development, financial aid services, and job placement services should be apportioned as they are services performed out of state...

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