No. 26,843.

199 P.3d 863 (2008)


DELL CATALOG SALES L.P., Protestant-Appellant, v. TAXATION AND REVENUE DEPARTMENT OF the State of NEW MEXICO, Respondent-Appellee.

Court of Appeals of New Mexico.

Certiorari Denied, No. 31,181, July 18, 2008.

Attorney(s) appearing for the Case

Freedman Boyd Daniels Hollander, Goldberg & Ives, P.A., John W. Boyd, Albuquerque, NM, Jones Day, Maryann B. Gall, Todd S. Swatsler, Laura A. Kulwicki, Columbus, OH, for Appellant.

Gary K. King, Attorney General, Peter Breen, Special Assistant Attorney General, Julia Belles, Special Assistant Attorney General, Santa Fe, NM, for Appellee.


FRY, Judge.

{1} Dell Catalog Sales L.P. (Taxpayer) appeals from a decision and order of a hearing officer of the New Mexico Taxation and Revenue Department (the Department). Pursuant to the Gross Receipts and Compensating Tax Act (the Act), NMSA 1978, §§ 7-9-1 to -111 (1966, as amended through 2007), the Department assessed gross receipts taxes on Taxpayer's mail-order computer sales and compensating taxes on Taxpayer's use...

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