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 case involves Loyal Services Agency, Inc. (Taxpayer), a corporation, seeking a refund of gross receipts taxes based on a deduction under NSMA 1978, Section 7-9-93(A) (2016, amended 2023). The deduction in question is typically available for health care practitioners. The Taxpayer contracted with a federal agency to provide services, asserting that the federal agency qualified as a managed health care provider for the purposes of the deduction.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellee (Taxpayer): Argued that it was entitled to a refund of gross receipts taxes based on the deduction provided for health care practitioners, as it contracted with a federal agency considered a managed health care provider.
• Defendants-Appellants (Department): Contended that the deduction is only available to individual health care practitioners and not to corporations, that the Taxpayer does not meet all criteria for the deduction, and that the regulations corresponding to Section 7-9-93 cannot extend the deduction's availability to entities like the Taxpayer.

Legal Issues

• Whether the deduction under NSMA 1978, Section 7-9-93(A) is available only to individual health care practitioners and not to corporations.
• Whether the Taxpayer satisfies all of the criteria for the deduction.
• Whether the regulations corresponding to Section 7-9-93 can expand the availability of the deduction to include entities like the Taxpayer.

Disposition

• The Court of Appeals affirmed the district court’s grant of summary judgment to the Taxpayer, concluding that the Taxpayer was entitled to the deduction and thus a refund of gross receipts taxes.

Reasons

• The Court, consisting of Judges Katherine A. Wray, Kristina Bogardus, and Zachary A. Ives, unanimously concurred in the decision. The Court found that the Department’s arguments regarding the availability of the deduction to corporations and the expansion of the deduction through regulations were already resolved in a recent case, Robison Med. Rsch. Grp. v. N.M. Tax’n & Revenue Dep’t, which held that an employer entity could take the deduction on behalf of an employee if the entity meets the statute's requirements and is not otherwise excluded. The Court also noted that the Department did not preserve its second argument regarding the necessity for the Taxpayer to establish that the receipts to be deducted were received pursuant to a contract between a health care practitioner and a managed health care provider, as it did not dispute the Taxpayer's assertions or the factual basis for them at the summary judgment stage (paras 1-3).