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 appellants, Jacob and Jeanne Kuriyan, submitted their 2009 New Mexico personal income tax return, claiming a refund for overpayment. They requested part of the refund be applied to their 2010 taxes, with the remainder refunded to them. The New Mexico Taxation and Revenue Department (the Department) did not act on the claim within the statutory 120 days. Nearly two years later, upon realizing they hadn't received their refund, the appellants inquired about the status. They were informed of a missing 2008 return, which they then submitted. Despite submitting applications for refunds for three separate years, including 2009, they did not receive the 2009 refund. The Department later denied the 2009 refund claim, citing a failure to file within the 3-year statute of limitations. The appellants protested this denial (paras 5-9).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellants: Argued that the Department should have been equitably estopped from asserting that they missed the 210-day deadline to file a civil action or protest the Department's inaction on their tax refund request. They contended that they met all requirements for equitable estoppel and that they were denied due process because they were not timely informed of the basis for the denial of their refund (paras 4, 15).
• Respondent: Maintained that the appellants failed to act within the 210-day deadline after the Department's inaction on their refund claim. The Department argued that it had no authority to allow the claim after the expiration of the 210 days and that the appellants' estoppel and due process arguments were not viable (paras 10, 14, 20).

Legal Issues

• Whether the Department should have been equitably estopped from arguing that the appellants missed the 210-day deadline to file a civil action or protest the Department’s inaction on their tax refund request.
• Whether the appellants were denied due process by the introduction of the 210-day deadline argument at the hearing.

Disposition

• The Court of Appeals affirmed the decision and order of the New Mexico Taxation and Revenue Department hearing officer, denying the appellants' motion to amend and their claims of equitable estoppel and due process violations (para 21).

Reasons

• The Court, per Chief Judge Michael E. Vigil, with Judges Jonathan B. Sutin and Stephen G. French concurring, held that the Department was not permitted under statute to allow the refund after the expiration of the 210-day time frame. The Court found the appellants' estoppel argument non-viable, noting that estoppel against a state entity requires a high degree of aggravated conduct or a compelling need for justice, which was not present in this case. The Court also rejected the appellants' due process argument, stating that they were directed to the relevant statute and that ignorance of the law does not excuse failure to act within legal deadlines. The Court concluded that the appellants were not denied due process when the Department raised the 210-day statutory deadline at the protest hearing (paras 10-20).