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 case concerns a dispute over property tax valuation for Federal Express Corporation's (FedEx) aircraft in New Mexico. FedEx made a computational error in reporting the ground time of its aircraft, which led to an overstatement of the property value allocated to New Mexico. This error resulted in an excessive property tax assessment. FedEx sought a refund, arguing the error was in the computation of taxes, not the valuation of property (paras 4, 9-10).
Procedural History
- District Court of Bernalillo County, Robert H. Scott, District Judge: Granted summary judgment in favor of FedEx, allowing its claim for a property tax refund (para 2).
Parties' Submissions
- Appellant (Bernalillo County Treasurer and New Mexico Taxation & Revenue Department): Argued that FedEx's error was in the valuation of property, not the computation of taxes, and that the claim was time-barred under the 60-day limit for valuation protests (paras 2, 10).
- Appellee (Federal Express Corporation): Contended that the error was a computational mistake in determining the aircraft's ground time, which falls under "errors in the computation of taxes" as per Section 7-38-78(B)(3), and thus subject to the general four-year statute of limitations (paras 4, 10).
Legal Issues
- Was the error made by FedEx in reporting its aircraft's ground time an error in the valuation of property or an error in the computation of taxes?
- Did FedEx file its claim for a refund within the applicable statutory time limit?
Disposition
- The Court of Appeals reversed the summary judgment in favor of FedEx and remanded the case for entry of judgment in favor of the Bernalillo County Treasurer (para 13).
Reasons
Per Wechsler CJ (Pickard and Sutin JJ. concurring):
The Court held that FedEx's error in reporting the ground time of its aircraft constituted an error in the valuation of property, not in the computation of taxes. The valuation process involved applying a formula to allocate the aircraft's value to New Mexico based on flight and ground time. FedEx's incorrect calculation of ground time directly affected the valuation, which was then used to compute the tax. The Court emphasized that Section 7-38-78(B)(3) does not encompass errors in valuation, and such claims must be filed within the 60-day limit under Section 7-38-40. Since FedEx failed to meet this deadline, its claim was time-barred. The Court relied on the plain language of the statute and prior case law to support its interpretation (paras 1, 10-12).