1 IN THE COURT OF APPEALS OF THE STATE OF NEW MEXICO JOSEPH and KATHY MAILANDER, 3 Petitioners-Appellants, v. No. 28,624 NEW MEXICO TAXATION and REVENUE DEPARTMENT, 7 Respondent-Appellee.

8 APPEAL FROM THE N.M. TAXATION AND REVENUE DEPARTMENT Margaret B. Alcock, Hearing Officer Law Offices of Daniel A. Dolan, PA Daniel A. Dolan Gerald S. O’Donnell Las Cruces, NM for Appellants N.M. Taxation and Revenue Dep’t Carolyn A. Wolf, Special Assistant Attorney General Santa Fe, NM for Appellee 19 MEMORANDUM OPINION SUTIN, Judge.

2 Summary affirmance was proposed for the reasons stated in the notice of proposed summary disposition. No memorandum opposing summary affirmance has been filed and the time for doing so has expired.

5 AFFIRMED.

6 IT IS SO ORDERED.

7 _________________________________ 8 JONATHAN B. SUTIN, Judge

9 WE CONCUR:

10 _________________________________ RODERICK T. KENNEDY, Judge

12 _________________________________ LINDA M. VANZI, Judge