This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Home Dialysis of New Mexico (Taxpayer) provides dialysis services to patients through licensed healthcare practitioners. The New Mexico Taxation and Revenue Department (the Department) assessed taxes against the Taxpayer, which claimed a deduction under the health care practitioner deduction statute, Section 7-9-93 NMSA 1978 (2023, amended 2024) (paras 1, 5).
Procedural History
- Administrative Hearings Office: Granted summary judgment in favor of Home Dialysis of New Mexico, determining that the Taxpayer qualifies for the health care practitioner deduction (para 1).
Parties' Submissions
- Appellant (New Mexico Taxation and Revenue Department): Argued that the Administrative Hearing Officer's decision was reviewed under an incorrect standard and that the Taxpayer does not qualify for the health care deduction. The Department also contended that the Taxpayer is excluded from claiming the deduction as it is a licensed facility under the Public Health Act (paras 2-3, 6-7).
- Appellee (Home Dialysis of New Mexico): Supported the Administrative Hearing Officer's decision, arguing that it qualifies for the health care deduction as it employs licensed healthcare practitioners and is not excluded under the statute (paras 1, 5).
Legal Issues
- Did the Administrative Hearing Officer apply the correct standard of review in granting summary judgment?
- Does Home Dialysis of New Mexico qualify for the health care practitioner deduction under Section 7-9-93 NMSA 1978?
- Is Home Dialysis of New Mexico excluded from claiming the deduction as a facility licensed under the Public Health Act?
- Did the Administrative Hearing Officer err in applying the evidentiary standard for summary judgment?
Disposition
- The New Mexico Court of Appeals affirmed the decision of the Administrative Hearing Officer, granting summary judgment in favor of Home Dialysis of New Mexico (para 11).
Reasons
Per Wray J. (Hanisee and Ives JJ. concurring):
The Court found that the Administrative Hearing Officer applied the correct standard of review, using the whole-record, administrative standard, which is appropriate for reviewing such decisions (para 3). The Court held that Home Dialysis of New Mexico qualifies for the health care practitioner deduction as it employs licensed healthcare practitioners, aligning with the precedent set in Robison Medical Research Group (para 4). The Court rejected the Department's argument that the Taxpayer is excluded from the deduction, clarifying that the exclusion applies only to entities solely operating as outpatient facilities licensed under the Public Health Act, which does not include the Taxpayer (paras 6-7). The Court also determined that the Administrative Hearing Officer correctly applied the evidentiary standard for summary judgment, as the Department failed to present sufficient evidence to create a genuine issue of material fact (para 9).