New Mexico Court of Appeals January 9, 2002, 21140 (Kmart Properties, Inc. v. Taxation & Revenue Department)

OPINION

BOSSON, Chief Judge.

{1} Kmart Properties, Incorporated (KPI), a wholly owned Michigan subsidiary of Kmart Corporation, owns and manages trademarks previously developed by Kmart Corporation. KPI challenges New Mexico’s assessment of state income taxes and gross receipts taxes upon royalties paid by Kmart Corporation to KPI.