Derek V. Larson



The taxpayer, a New Mexico resident, made out-of-state purchases of a car and a travel trailer and brought both back to be titled and registered in New Mexico.  At the time of titling and registration, the taxpayer paid New Mexico motor vehicle excise tax.  He then submitted requests for refund of the tax, and, when the requests were denied, protested the denials, claiming that vehicles purchased outside New Mexico are not subject to New Mexico motor vehicle excise tax when they are titled and registered in this state.  The hearing officer denied the protests, finding that, except for specifically stated exemptions, the Motor Vehicle Excise Tax Act imposes on every applicant for a New Mexico certificate of title an excise tax equal to three percent of the price paid for the vehicle, including vehicles purchased outside the state.