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 taxpayers, owners of dairy cattle in Dona Ana County, filed a claim for a property tax refund, alleging that their cattle were overvalued. They initiated the claim in Santa Fe County, uncertain about where the cattle were valued for tax purposes. A similar action was also filed in Dona Ana County. The Santa Fe County court determined that the cattle were valued in Dona Ana County and dismissed the taxpayers' action. The Dona Ana County action remains pending (paras 2-3).
Procedural History
- District Court of Santa Fe County: Dismissed the taxpayers' claim for a property tax refund, concluding that the cattle were valued in Dona Ana County (paras 2-3).
Parties' Submissions
- Plaintiffs-Appellants (Taxpayers): Argued that the Property Tax Code creates a conflict between Sections 7-36-2 and 7-36-21, asserting that the Property Tax Division, not the county assessor, was responsible for valuing their livestock. They contended that this interpretation justified filing their refund claim in Santa Fe County (paras 3, 6).
- Defendant-Appellee (Director, Property Tax Division): [Not applicable or not found]
Legal Issues
- Whether the Property Tax Code allocates the responsibility for valuing livestock to the Property Tax Division or the county assessor.
- Whether the taxpayers' refund claim was properly filed in Santa Fe County.
Disposition
- The Court of Appeals affirmed the dismissal of the taxpayers' action in Santa Fe County (para 11).
Reasons
Per Alarid CJ (Pickard and Flores JJ. concurring):
The Court found no conflict between Sections 7-36-2 and 7-36-21 of the Property Tax Code. Section 7-36-2 assigns valuation responsibility for livestock to the county assessor, while Section 7-36-21 requires the Property Tax Division to establish general classifications and values for livestock, which the county assessor applies. The actual valuation is performed by the county assessor, even if guided by the Division's rules. The Court emphasized that statutes should be interpreted to give effect to all provisions and found that the taxpayers' interpretation was inconsistent with the statutory framework. Consequently, the trial court's dismissal of the Santa Fe County action was proper under Section 7-38-40(A) (paras 7-10).