OPINION
SERNA, Chief Justice.
{1} This Court granted the petition of James A. Holt and Terri L. Holt (taxpayers) for writ of certiorari to the Court of Appeals following its affirmance of the New Mexico Department of Taxation and Revenue (Department) hearing officer's denial of their protest and request for a refund. Holt v. N.M. Dep't of Taxation & Revenue, NMCA 22,622, slip op. at 1 (Mar. 5, 2002), cert. granted, 132 N.M. 193,...
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