AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Taxpayer, CIBL, Inc. & Subsidiaries, filed a claim for a tax refund with the New Mexico Taxation and Revenue Department. The Department denied the claim as untimely because the Taxpayer did not submit an amended tax return before the statute of limitations expired. The Taxpayer had met all other statutory requirements for a refund claim within the deadline. The Department's decision was based on an additional requirement found in an administrative regulation, which mandates the submission of a fully completed amended return for each period a refund is claimed (paras 2-4).

Procedural History

• Administrative Hearings Office: The hearing officer granted summary judgment in favor of the Department, ruling that the Taxpayer's claim was barred due to non-compliance with the regulation requiring an amended return before the statute of limitations expired (para 1).

Parties' Submissions

• Taxpayer: Argued that the claim was timely as it complied with all statutory requirements before the limitations period expired. Contended that the regulation adding the requirement of an amended return could not bar a claim that complies with the statute (paras 1, 5).
• Department: Maintained that the Taxpayer's claim was untimely because it did not include an amended return as required by the administrative regulation before the statute of limitations ran. Argued that the regulation was a proper implementation of the law and that it has the authority to promulgate regulations to implement tax acts (paras 4, 10).

Legal Issues

• Whether the Taxpayer's claim for a tax refund was untimely due to the failure to submit an amended tax return before the statute of limitations expired, despite meeting all other statutory requirements.
• Whether the administrative regulation adding the requirement of an amended return can bar a claim that complies with the statute.

Disposition

• The Court of Appeals reversed the hearing officer’s decision, concluding that the Taxpayer’s claim for a tax refund was timely filed under the statute and remanded for further proceedings consistent with this opinion (para 12).

Reasons

• The Court, per Judge Megan P. Duffy, with Chief Judge J. Miles Hanisee and Judge Zachary A. Ives concurring, found that the Taxpayer complied with all statutory requirements for submitting a claim for a tax refund before the limitations period expired. The Court held that the additional requirement of submitting an amended return, as per the Department's regulation, could not bar a claim that complies with the statute. The Court reasoned that the statute and the regulation were in conflict because they addressed the same issue but provided for different results, and in such cases, the language of the statute must prevail. The Court also noted that the Department's argument that the regulation was a proper implementation of the law did not address the inconsistency identified by the Taxpayer. Furthermore, the Court observed that the Legislature had resolved the conflict between the statute and the regulation by amending the statute to include the requirement of an amended return, but this amendment did not apply retroactively to the Taxpayer's claim (paras 5-11).