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

• Casias Trucking, engaged in intra-state hauling of construction materials, was audited by the New Mexico Taxation and Revenue Department for suspected underreporting of weight distance taxes for 2004 through 2009. The Department's audit concluded that Casias Trucking had significantly underreported its mileage, leading to a substantial tax assessment against the company. Casias Trucking protested the assessment, arguing that the Department's audit methodology was unreliable and that its own records, particularly fuel receipts, provided a more accurate account of mileage and taxes owed (paras 2-4, 12-14).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellant (New Mexico Taxation & Revenue Department): Argued that Casias Trucking's records were inadequate for calculating the weight distance tax, justifying the use of an alternative audit methodology which resulted in a higher tax assessment (paras 9-12).
• Appellee (Casias Trucking): Contended that the Department's audit methodology produced unreasonably high results and that their own records, especially fuel receipts, were a reliable basis for calculating mileage and the corresponding tax (paras 13-15).

Legal Issues

• Whether the hearing officer correctly concluded that the Department’s method for calculating the amount of taxes owed by Casias Trucking was unreliable (para 1).
• Whether Casias Trucking's records, particularly fuel receipts, provided a reliable basis for calculating mileage and taxes owed (paras 13-18).

Disposition

• The court affirmed the hearing officer's decision that the Department’s method for calculating the amount of taxes owed by Casias Trucking was unreliable and abated the assessment (para 1).

Reasons

• Judges Michael E. Vigil, Timothy L. Garcia, and J. Miles Hanisee: Found that the hearing officer's decision was supported by substantial evidence. The court held that the hearing officer correctly determined that Casias Trucking's fuel receipts were reliable and not contradicted by the Department's evidence. The court also agreed with the hearing officer that Casias Trucking had overcome the presumption of correctness of the Department's assessment and that the Department failed to prove the correctness of its assessment. The court emphasized that it does not reweigh evidence or substitute its judgment for that of the fact finder, affirming the hearing officer's credibility determinations and findings (paras 19-27).