OPINION
PICKARD, Judge.
{1} Plaintiff, Public Service Company of New Mexico (PNM), a public utility in the business of generating and selling electricity, appeals from a district court order granting summary judgment in favor of Defendants, New Mexico Taxation and Revenue Department (the Department). On appeal, PNM challenges the Department's denial of a refund for a compensating tax levied upon PNM's purchase of turbines and related equipment for use in...
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