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

• Two corporations, ISD Renal, Inc. and Total Renal Care, Inc., operating end-stage renal disease facilities, sought refunds for gross receipts taxes, arguing they were entitled to a tax deduction as healthcare facilities employing health care practitioners. The New Mexico Taxation and Revenue Department denied these refund requests, leading to the corporations' protests.

Procedural History

• Administrative Hearings Office: The Administrative Hearing Officer granted summary judgment to the Taxpayers, concluding they were entitled to the tax deduction as end-stage renal disease facilities employing health care practitioners and were not exempted as outpatient facilities.

Parties' Submissions

• Taxpayers: Argued they qualify for a gross receipts tax deduction under NMSA 1978, Section 7-9-93(A) and related regulations as they are end-stage renal disease facilities employing health care practitioners, specifically registered nurses, and are not classified as outpatient facilities under the Public Health Act.
• Respondent (New Mexico Taxation & Revenue Department): Contended that the Taxpayers do not qualify for the deduction as they are not individual health care practitioners but rather entities, and claimed they are outpatient facilities exempt from the deduction. Additionally, argued that the Department is not estopped from withholding relief from Taxpayers.

Legal Issues

• Whether Taxpayers, as end-stage renal disease facilities employing health care practitioners, qualify for a gross receipts tax deduction.
• Whether Taxpayers are considered outpatient facilities and thus exempt from the deduction.
• Whether the Department is estopped from withholding relief from Taxpayers based on their compliance with regulations effective at the time the tax liability arose.

Disposition

• The Court affirmed the Administrative Hearing Officer's decision granting summary judgment to the Taxpayers, allowing them the tax deduction and concluding the Department was estopped from withholding relief.

Reasons

• The Court, consisting of Judges Jacqueline R. Medina, Jennifer L. Attrep, and Gerald E. Baca, held that Taxpayers qualify for the tax deduction as they employ health care practitioners (registered nurses) and are not classified as outpatient facilities under the Public Health Act. The Court found that the Department's interpretation of the relevant statutes and regulations was incorrect and that the Taxpayers' operations as end-stage renal disease facilities did not exempt them from receiving the deduction. Furthermore, the Court concluded that the Department was estopped from withholding the deduction because the Taxpayers acted in accordance with the regulations effective at the time their tax liability arose (paras 1-15).