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

• Four Corners Healthcare Corporation, a licensed home health agency, provided services to United States Department of Energy employees under the Energy Employees Occupational Illness Compensation Program Act (EEOICPA), receiving compensation from the Department of Labor, not Medicare. Concerned about its tax liability, Four Corners filed nineteen applications for a refund of gross receipts taxes amounting to $1,325,343.10 for the period between January 2014 and September 2016, which were denied by the New Mexico Taxation and Revenue Department (para 3).

Procedural History

• Administrative Hearings Office: The hearing officer denied Taxpayer’s protest of the denial of refund issued under Letter ID No. L1522048304 (para 1).

Parties' Submissions

• Protestant-Appellant (Four Corners Healthcare Corporation): Argued that it was entitled to deduct the entirety of its gross receipts based on specific sections of the NMSA 1978, contending that the services provided were deductible from gross receipts taxes (paras 5-6, 12).
• Respondent-Appellee (New Mexico Taxation & Revenue Department): Maintained that the taxpayer did not meet the burden to establish it was clearly entitled to the statutory deduction, arguing against the applicability of the deductions under the cited sections of the NMSA 1978 (paras 5-6, 12).

Legal Issues

• Whether the taxpayer was entitled to deduct the entirety of its gross receipts based on NMSA 1978, Section 7-9-93 (2007, amended 2022) and NMSA 1978, Section 7-9-77.1 (2016, amended 2021) (paras 5, 12).

Disposition

• The appeal was affirmed, denying the taxpayer's entitlement to the deductions claimed under the specified sections of the NMSA 1978 (para 14).

Reasons

• The Court, comprising Judge Katherine A. Wray, with Judges Kristina Bogardus and Zachary A. Ives concurring, reasoned that deductions from gross receipts taxes are construed strictly against the taxpayer, and it is the taxpayer’s burden to show clear entitlement to the statutory deduction. The Court found that the taxpayer did not establish clear entitlement to a deduction under Section 7-9-93 (2007) because the services provided did not qualify as deductible under the specific provisions of the Gross Receipts and Compensating Tax Act. Furthermore, the Court rejected the taxpayer's entitlement to a deduction under Section 7-9-77.1(E) (2016), as the services were not provided pursuant to Medicare but were instead provided entirely pursuant to EEOICPA. The Court's interpretation of the statutes and regulations led to the conclusion that the taxpayer failed to meet the burden of establishing clear entitlement to the deductions claimed (paras 5-13).