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

• Cable One, Inc., a company providing cable television, internet, and Voice over Internet Protocol (VoIP) services in New Mexico, was reclassified by the New Mexico Taxation and Revenue Department as a "communications system" under the Property Tax Code. This reclassification subjected Cable One's tangible property to central assessment and valuation by the Department, a decision Cable One contested. Cable One argued that its property should not be considered part of a communications system and sought a refund for taxes paid under protest for the years 2013 and 2014 (paras 2-4, 6-7).

Procedural History

• District Court of Santa Fe County: Granted in part Cable One's motion for summary judgment, concluding Cable One's property is not part of a "communications system" under the Property Tax Code, and ordered the Department to refund Cable One for overpaid taxes for 2013 and 2014 (paras 6-7).

Parties' Submissions

• Plaintiff-Appellee (Cable One, Inc.): Argued that its property does not come within the definition of "communications system" as per the Property Tax Code, contending that the Department's reliance on the statutory definition failed to consider the Code's overall scheme and legislative intent. Cable One also highlighted the lack of a "plant" property and the failure of legislative amendments as evidence against central assessment (paras 4, 13-14).
• Defendants-Appellants (New Mexico Taxation and Revenue Department): Contended that Cable One's repurposing of its system to provide two-way communication services transformed its business into a communications system as defined in the Property Tax Code, thereby subjecting it to central assessment. The Department argued that the statutory definition of "communications system" clearly applied to Cable One's operations (paras 3, 5, 8, 11).

Legal Issues

• Whether Cable One, Inc.'s property qualifies as a "communications system" under the Property Tax Code, thereby subjecting it to central assessment and valuation by the New Mexico Taxation and Revenue Department (para 8).

Disposition

• The Court of Appeals reversed the district court's decision, concluding that Cable One's property falls within the definition of "communications system" under the Property Tax Code and is subject to central assessment by the Department (para 29).

Reasons

• Per J. Miles Hanisee (Michael E. Vigil and M. Monica Zamora, Judges concurring): The court held that Cable One's property meets the statutory definition of "communications system" as it is used for the transmission and reception of information by electronic, magnetic, or optical means and is available for use by others for consideration. The court found no ambiguity in the statute's language and determined that the Legislature intended for such property to be classified and assessed centrally. The court also addressed and dismissed Cable One's arguments regarding legislative intent, the failure of a bill to amend the definition, and the Department's alleged overreach, concluding that the Department's classification and assessment of Cable One's property were consistent with the Property Tax Code and legislative intent (paras 10-29).