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Dr. Christopher Nelson



TP was engaged in business in NM as a Chiropractor. The TP had retired his CRS registration number some years ago and had not reported or paid gross receipts tax or income tax on his receipts or income from performing chiropractic services. The department issued estimated assessments of gross receipts and income tax, and assessed a 50% fraud penalty. The department failed to prove that the TP intended to defraud the state. The TP’s protest of the fraud penalty was granted, and the remainder of the protest was denied.