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

• Santa Fe Tow and Emergency Lock & Key (the Protestants-Appellants) protested against assessments issued by the New Mexico Taxation and Revenue Department under specific identification numbers. The nature of the assessments and the reasons for the protest are not detailed in the available information.

Procedural History

• Appeal from the Taxation & Revenue Department, Monica Ontiveros, Hearing Officer.

Parties' Submissions

• Protestants-Appellants: The specific arguments made by Santa Fe Tow and Emergency Lock & Key are not detailed in the available information (N/A).
• Respondent-Appellee: The New Mexico Taxation and Revenue Department's specific counterarguments to the protest are not detailed in the available information.

Legal Issues

• Whether the Taxation & Revenue Department's assessments against Santa Fe Tow and Emergency Lock & Key were valid.

Disposition

• The Court of Appeals of New Mexico affirmed the decision of the Taxation & Revenue Department (para 2).

Reasons

• Per Roderick T. Kennedy, J. (Michael E. Vigil, Chief Judge, and Jonathan B. Sutin, Judge, concurring):
  The decision to affirm the Taxation & Revenue Department's assessments was based on the reasons stated in the notice of proposed summary disposition. No memorandum opposing summary affirmance was filed, and the time for doing so expired, leading to the affirmation of the lower decision without further detailed reasoning provided (paras 1-3).