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HIGH DESERT v. N.M. TAX'N & REVENUE DEP'T

No. A-1-CA-37852.

517 P.3d 258 (2021)

2022-NMCA-048

HIGH DESERT RECOVERY, LLC, Protestant-Appellant, v. NEW MEXICO TAXATION & REVENUE DEPARTMENT, Respondent-Appellee.

Court of Appeals of New Mexico.

Certiorari Denied, June 27, 2022, No. S-1-SC-39162.

Attorney(s) appearing for the Case

Sanchez, Mowrer & Desiderio, P.C., Robert J. Desiderio , Isaac S. Emmanuel , Albuquerque, NM, Betzer, Roybal & Eisenberg, P.C., Benjamin C. Roybal , Albuquerque, NM, for Appellant.

Hector H. Balderas , Attorney General, Cordelia Friedman , Special Assistant Attorney General, Santa Fe, NM, for Appellee.

OPINION

{1} This appeal concerns the State's effort to collect unpaid gross receipts taxes from High Desert Recovery, LLC (High Desert). High Desert appeals from an Administrative Hearing Officer's (AHO) decision and order (the Order) determining it to be a successor in business, as well as a mere continuation...

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