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PCA v. TAXATION AND REVENUE DEPT.

No. 20,078.

999 P.2d 1031 (2000)

128 N.M. 799

2000-NMCA-021

PRODUCTION CREDIT ASSOCIATION OF EASTERN NEW MEXICO, Appellant, v. TAXATION AND REVENUE DEPARTMENT OF the STATE OF NEW MEXICO, Appellee.

Court of Appeals of New Mexico.

Certiorari Denied March 13, 2000.

Attorney(s) appearing for the Case

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

Patricia A. Madrid, Attorney General, David C. Iglesias, Chief Counsel, Monica M. Ontiveros, Special Assistant Attorney General, Taxation and Revenue Department, Santa Fe, Frank D. Katz, Special Assistant Attorney General, Santa Fe, NM, for Appellee.

Certiorari Denied, No. 26,211, March 13, 2000.

OPINION

PICKARD, Chief Judge.

{1} Production Credit Association of Eastern New Mexico (PCA) filed a claim for refund of New Mexico corporate income and franchise taxes for the 1992-1996 tax years with the New Mexico Taxation and Revenue Department (Department). PCA claimed it was entitled to a refund because (1) Congress declared production credit associations like PCA to be federal instrumentalities...

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