NMSA 1978, § 7-1-60 — Estoppel against state

In any proceeding pursuant to the provisions of the Tax Administration Act, the
department shall be estopped from obtaining or withholding the relief requested if it is
shown by the party adverse to the department that the party's action or inaction
complained of was in accordance with any regulation effective during the time the
asserted liability for tax arose or in accordance with any ruling addressed to the party
personally and in writing by the secretary, unless the ruling had been rendered invalid or
had been superseded by regulation or by another ruling similarly addressed at the time
the asserted liability for tax arose.