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NM D&O 03-20 Gross Receipts Tax 2003-10-28

Could James Crowe avoid New Mexico gross receipts tax on $28,875 from an Albuquerque company by testifying that much of his marketing work occurred out of state after he destroyed the supporting records?

Short answer: No. The Department accepted Terry Crowe's 1099s as proof that her $4,900 of consulting services occurred outside New Mexico, but James Crowe could not document where he performed work for Albuquerque-based EchoPort. He had discarded his contract, expense reports, and travel receipts and admitted doing some work in the Albuquerque office. He failed to overcome the assessment and taxable-receipts presumptions, so both assessments were upheld.

Apply this to your situation

This page answers the general question as of 2003. Ezel answers yours, under current New Mexico tax law, with citations.

Currency note: this ruling is from 2003
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is a published Decision and Order of the New Mexico Administrative Hearings Office, an independent agency that adjudicates tax protests separately from the Taxation and Revenue Department. It resolves one taxpayer's protest on the specific facts and the law in effect when issued; different facts or later changes in the law can change the result, and another taxpayer should not assume it applies to their situation. A Decision and Order binds the parties to that protest and is not a general ruling or advisory opinion of the Department. This summary is informational only and is not legal or tax advice. Consult a licensed New Mexico tax professional about your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

James Crowe could not exclude his EchoPort compensation from New Mexico gross receipts tax because he had destroyed the records needed to prove that the services were performed outside the state. His testimony showed that at least some work occurred in EchoPort's Albuquerque office, and he could not establish the location or duration of the claimed out-of-state work.

James and Terry Crowe were New Mexico residents in 2000. Terry Crowe received $4,900 for consulting work for universities in Louisiana and Illinois. James Crowe received $28,875 from Albuquerque-based EchoPort for business-development and marketing services.

Both amounts appeared on federal Schedule C, but the Crowes did not report New Mexico gross receipts tax. After an IRS information match, the Department investigated.

The Department accepted documented out-of-state services

Terry Crowe provided Forms 1099 from Louisiana State University and North Park University. The Department accepted those documents as evidence that her services were performed outside New Mexico.

For James Crowe, the Department asked for a statement from EchoPort or other records showing which services were performed outside New Mexico rather than at its Albuquerque office. EchoPort was no longer operating, and Crowe said he had lost contact with its principals.

Some work occurred in Albuquerque

Crowe had been hired to help market EchoPort's remote tank-monitoring device. He spent time in the Albuquerque office consulting with managers and calling potential customers.

He also traveled to meet out-of-state prospects, and EchoPort arranged travel and reimbursed his cash expenses. But at the hearing he could identify only two prospects—Culligan Water in Chicago and PraxAir in Mississippi—and gave no dates or time allocations for those meetings.

Destroyed records left the claim unproved

The protest auditor suggested evidence that could support the claim, including the EchoPort contract, travel receipts, canceled checks, trade-show records, and documents from customers.

Crowe had thrown away his contract, expense reports, travel receipts, and other papers relating to the work. Sections 7-1-10(A) and 7-1-11(C) required taxpayers to maintain records permitting accurate tax computation and make them available to the Department.

Without those records or comparable third-party evidence, the hearing officer could not determine what portion of the services occurred outside New Mexico.

The statutory presumptions controlled

Section 7-1-17(C) presumed the Department's assessment correct, and Section 7-9-5 presumed receipts from engaging in business taxable. Crowe bore the burden of overcoming both presumptions.

His general testimony that EchoPort's potential customers were outside New Mexico did not prove where he performed the compensated services. The decision therefore found no basis for an abatement.

Result: protest DENIED. The Department upheld two assessments totaling $1,586.16 of tax, $158.62 of penalty, and $616.51 of interest for the two halves of 2000.

What this means for you

Consultants working in several states

Track where each service is actually performed, not just where the customer is located. Preserve calendars, travel records, contracts, work logs, and customer correspondence.

Contractors paid by an in-state company

An out-of-state customer list does not by itself prove out-of-state performance when office work, calls, and management meetings occur in New Mexico.

Businesses discarding old records

Keep tax-supporting records through the applicable audit and protest periods. Once records are destroyed, testimony may not be enough to allocate receipts.

Taxpayers responding to a limited-scope audit

Use the auditor's document requests as a checklist. Third-party documents can sometimes replace records from a company that has closed.

Common questions

Q: Why was Terry Crowe's $4,900 accepted as out-of-state?
A: Her Forms 1099 identified the Louisiana and Illinois universities for which she performed consulting services.

Q: How much did James Crowe receive from EchoPort?
A: $28,875 in 2000.

Q: Did he perform any work in New Mexico?
A: Yes. He acknowledged spending time in EchoPort's Albuquerque office consulting with managers and contacting prospects.

Q: Which records were missing?
A: His contract, expense reports, travel receipts, and other documents that could show when and where he worked.

Q: Who had the burden of proof?
A: Crowe, because New Mexico law presumed both the assessments and business receipts taxable.

Citations and references

Statutes:

  • NMSA 1978, § 7-1-17(C) — presumption that a Department assessment is correct
  • NMSA 1978, § 7-9-5 — presumption that business receipts are subject to gross receipts tax
  • NMSA 1978, § 7-1-10(A) — duty to maintain records permitting accurate tax computation
  • NMSA 1978, § 7-1-11(C) — duty to make records available for Department inspection

Cases cited:

  • Archuleta v. O'Cheskey, 84 N.M. 428, 504 P.2d 638 (Ct. App. 1972)
  • Wing Pawn Shop v. Taxation and Revenue Department, 111 N.M. 735, 809 P.2d 649 (Ct. App. 1991)
  • Al Zuni Traders v. Bureau of Revenue, 90 N.M. 258, 561 P.2d 1351 (Ct. App. 1977)

Source

Original ruling text

BEFORE THE HEARING OFFICER
OF THE TAXATION AND REVENUE DEPARTMENT
OF THE STATE OF NEW MEXICO

IN THE MATTER OF THE PROTEST OF
JAMES M. AND TERRY K. CROWE No. 03-20
ID NO. 02-953793-00-2
ASSESSMENT NOS. 4068034 and 4068036

DECISION AND ORDER

A formal hearing on the above-referenced protest was held October 23, 2003, before

Margaret B. Alcock, Hearing Officer. The Taxation and Revenue Department ("Department") was

represented by Jeffrey W. Loubet, Special Assistant Attorney General. James M. Crowe (“Taxpayer”)

represented himself. Based on the evidence and arguments presented, IT IS DECIDED AND

ORDERED AS FOLLOWS:

FINDINGS OF FACT

  1. James and Terry Crowe were residents of New Mexico during the 2000 tax year.

  2. Dr. Terry Crowe worked at the University of New Mexico and also did consulting

work for Louisiana State University in New Orleans and North Park University in Chicago.

  1. Dr. Crow was paid $4,900 for the consulting services she performed in Louisiana and

Illinois during 2000.

  1. In June or July 2000, James Crowe was hired as the Business Development Manager

for EchoPort, Inc., a small company with offices located in Albuquerque, New Mexico.

  1. EchoPort had developed a wireless device that allowed the level of liquid in a tank to

be monitored electronically, thereby saving the time and expense of having a person manually check

the fluid level.

  1. Mr. Crowe had experience with start-up companies in California and was hired to

help EchoPort market its remote sensing device.

  1. Mr. Crowe spent some time at EchoPort’s Albuquerque office consulting with the

company’s managers and using the telephone to contact potential customers, which included

Culligan Water in Chicago and PraxAir in Mississippi.

  1. Mr. Crowe received a flat fee of $5,000 per month for his services.

  2. When Mr. Crowe traveled out-of-state to meet with potential customers, EchoPort

made all of the travel arrangements and paid for his expenses.

  1. When Mr. Crowe incurred out-of-pocket expenses for such items as meals, tolls,

parking, etc., he paid in cash and then submitted his receipts and an expense report to receive

reimbursement from EchoPort.

  1. Mr. Crowe’s work with EchoPort ended in December 2000.

  2. When James and Terry Crowe filed their 2000 federal income tax return, they

reported the $4,900 Dr. Crowe received from her consulting services and the $28,875 Mr. Crowe

received from his services for EchoPort on Schedule C to federal Form 1040.

  1. The Crowes filed New Mexico personal income tax returns for 2000, but did not ask

their accountant whether their compensation was also subject to the New Mexico gross receipts tax.

  1. As part of an information-sharing program with the Internal Revenue Service, the

Department was notified of the business income reported on the Crowes’ 2000 federal income tax

return. When the Department investigated, it found that neither of the Crowes was registered with

the Department for payment of gross receipts tax.

  1. On April 25, 2003, the Department sent the Crowes a Notice of Limited Scope Audit

asking them to explain why they had not reported gross receipts tax on their 2000 business income.

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  1. In response to the Department’s notice, Mr. Crowe sent the Department copies of the

Form 1099s his wife received for her consulting services and the Form 1099 he received from

EchoPort.

  1. The Department accepted the 1099s from Louisiana State University and North Park

University as evidence that Dr. Crowe’s services were performed outside New Mexico.

  1. Because EchoPort was based in Albuquerque, New Mexico, the Department asked

Mr. Crowe to provide a statement from someone at EchoPort that would explain the nature of Mr.

Crowe’s services and establish that those services were performed out-of-state rather than in

Albuquerque.

  1. Mr. Crowe stated that he could not provide any documentation concerning the nature

of his activities because EchoPort was no longer in business and he had lost contact with its

principals.

  1. On June 3, 2003, the Department issued the following assessments to the Crowes:

Assessment Report Period Tax Penalty Interest

4068034 1/00-6/00 $793.08 $ 79.31 $338.17
4068036 7/00-12/00 $793.08 $ 79.31 $278.34

  1. On June 3, 2003, Mr. Crowe filed a written protest to the Department’s assessments.

  2. After the protest was filed, the Department’s protest auditor wrote several letters to

Mr. Crowe with suggestions as to the kinds of documents that could serve as evidence that his

services were performed outside New Mexico. The list of documents the auditor requested from Mr.

Crowe included his contract with EchoPort, travel receipts, canceled checks, or third party

documents from trade shows he attended or customers he met with.

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  1. Mr. Crowe told the Department that he had thrown out all of the paperwork related to

his work with EchoPort, including his employment contract and his expense reports and travel

receipts, and did not have any documents that would establish his out-of-state travel during the 2000

tax year.

DISCUSSION

The Taxpayer maintains that the Department erroneously assessed gross receipts tax on

payments he received for performing services outside New Mexico. The Department responds that

the Taxpayer’s records were inadequate to establish what portion of the Taxpayer’s work was

performed at EchoPort’s Albuquerque office and what portion was performed out-of-state.

NMSA 1978, § 7-1-17(C) provides that any assessment of tax by the Department is

presumed to be correct, and it is the taxpayer's burden to overcome this presumption. Archuleta v.

O'Cheskey, 84 N.M. 428, 431, 504 P.2d 638, 641 (Ct. App. 1972); Wing Pawn Shop, 111 N.M. 735,

741, 809 P.2d 649, 655 (Ct. App. 1991). Additionally, "it is presumed that all receipts of a person

engaging in business are subject to the gross receipts tax." NMSA 1978, § 7-9-5. In this case, the

Taxpayer was unable to provide any records or other evidence to show that his services for EchoPort

were performed outside New Mexico. At the administrative hearing, the Taxpayer acknowledged that

he spent at least some time in EchoPort’s Albuquerque office meeting with the company’s managers

and making telephone calls. Although the Taxpayer testified that all of the companies to which

EchoPort marketed its sensing device were located out-of-state, he was able to identify only two of

those companies: Culligan Water and PraxAir. The Taxpayer did not provide any information

concerning the dates or length of time that he spent meeting with these companies.

NMSA 1978, § 7-1-10(A) requires every person to "maintain books of account or other

records in a manner that will permit the accurate computation of state taxes...." NMSA 1978, § 7-1-

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11(C) states that taxpayers “shall upon request make their records and books of account available for

inspection at reasonable hours to the secretary or the secretary's delegate.” The Taxpayer in this case

testified that he destroyed all of the records pertaining to his work with EchoPort, including his

employment contract and travel receipts. In Al Zuni Traders v. Bureau of Revenue, 90 N.M. 258,

561 P.2d 1351 (Ct. App. 1977), the New Mexico Court of Appeals held that the Department is not

required to allow an exemption or deduction for out-of-state sales when the taxpayer is unable to

provide proof of such sales. As stated by the court: “Taxpayer seeks to burden the Commissioner

with proof that its sales were not interstate. The burden, however, rests squarely on the taxpayer to

prove entitlement to an exemption.” 90 N.M. at 260, 561 P.2d at 1353. The same holds true in this

case. In the absence of any records or other credible evidence to show that his services for EchoPort

were performed outside New Mexico, the Taxpayer has failed to meet his burden of proof, and there

is no basis for an abatement of the Department’s assessment against him.

CONCLUSIONS OF LAW

  1. The Taxpayer filed a timely, written protest to Assessment Nos. 4068034 and 4068036,

and jurisdiction lies over the parties and the subject matter of this protest.

  1. The Taxpayer failed to meet his burden of proving that the Department’s assessment

was incorrect.

For the foregoing reasons, the Taxpayer's protest IS DENIED.

DATED October 28, 2003.

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