Wolf Corporation



Taxpayer is a corporation engaged in business in New Mexico.  Due to the large dollar volume of the Taxpayer’s business, the Taxpayer is required to pay its monthly CRS taxes according to special payment procedures set out in Section 7-1-13.1 NMSA 1978. In March 2000, the Department issued an assessment to the Taxpayer for penalty and interest due on the late payment of the Taxpayer’s February 2000 CRS taxes. Taxpayer filed a written protest to the assessment.  The Taxpayer asserts the law applied in this situation is excessively harsh and asks the hearing officer to exercise “judicial discretion” to relieve the Taxpayer of a portion of the assessment. Held:  The hearing officer does not have authority to override the provisions of Sections 7-1-67 and 7-1-69 NMSA 1978.  Protest Denied.