Opposition Brief — Production Credit Ass'n of Eastern New Mexico v. Taxation & Revenue Department

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la) AUS 28

SD B 2000

No. 00-156 —

In The

Supreme Court of the Hnited States

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PRODUCTION CREDIT ASSOCIATION

OF EASTERN NEW MEXICO,

Petitioner,

TAXATION AND REVENUE DEPARTMENT

OF THE STATE OF NEW MEXICO,

Respondent.

‘

On Petition For A Writ Of Certiorari

To The Court Of Appeals Of New Mexico

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BRIEF IN OPPOSITION

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PatriciA MADRID

Attorney General

DonaLp F. Harris*

Bruce J. Fort

Special Assistant Attorneys

General

Post Office Box 630

Santa Fe, New Mexico 87504-0630

(505) 841-6583

Counsel for New Mexico Taxation

and Revenue Department

*Counsel of Record

COCKLE LAW BRIEF PRINTING CO., (800) 225-6964

OR CALL COLLECT (402) 342-2831

QUESTION PRESENTED

Did Congress intend to eliminate the States’ long-

standing authority to tax privately-owned Production

Credit Associations when it amended 12 U.S.C. § 2077 in

1985?

ii

TABLE OF CONTENTS

Page

GAIGSTION PISO a Reds So oss ache eee eens i

TABLE OF CARN is crock eer ceeenaaee ii

TABLE CP AURA iss cre eckicsoexeasaveees iii

STATEMENT CP THER CADE on os i cece chives cones 1

A. History of the Production Credit Associations.. 2

S. Die Teen BO oki iho aea a eee ee 4

C. Beinotabeineis: OF Flic i ee eek eee 5

REASONS FOR DENYING THE WRIT............. 6

A. CERTIORARI SHOULD NOT BE GRANTED

WHERE THE SAME QUESTION IS CURRENTLY

5k ee, eae) ee erEe eee Te rer rs: oe 6

B. CERTIORARI SHOULD NOT BE GRANTED

WHERE THE COURT BELOW CORRECTLY

DETERMINED THAT CONGRESS’ INTENT TO

SUBJECT PCAs TO STATE INCOME TAX WAS

CLEAR, OBVIATING THE NEED FOR IMPLY-

ING AN IMMUNITY UNDER McCULLOCH v.

PELL UMRINGE 0. 5-0 955 6a RAN ENA OE REN TEAS SET 7

1. Where a Limited Immunity is Established by

Statute, No Broader Immunity Should Ordi-

ATTY DO TUNING a6 5.550 3 cen Wes neeeceeee 7

2. PCAs Are Not So Closely Connected to the

Federal Government as to Require a Presump-

tion of Immunity from State Taxation ........ 9

CARATS oe kh a3 i 554 VEER RA TRS en 13

ill

TABLE OF AUTHORITIES

Page

Cases

Andrews v. Federal Home Land Bank of Atlanta, 998

RO OE BOE EM PPMD sv vetccscceetesenccdasnens 10

Arkansas v. Farm Credit Services of Central Arkansas,

a Ua vd dv acess es eke Ne viens ee 9, 10

Cotton Petroleum Corp. v. New Mexico, 490 U.S. 163

ES TAEEE Feb We Lah eks ALKA AS SKA SAS cada Kwa s 11

Department of Revenue of Oregon v. ACF Industries,

es WE Uy UIE MPa OU CEWOED cv vicc cans cccsscccases 8

Director of Revenue v. CoBank, ACB, No. 99-1972

(cert. granted, June 26, 2000) ..................... 1, 6

Farm Credit Serv. of Mid-America v. Department of

State Revenue, 705 N.E. 2d 1089 (Ind. Tx. Ct.

LT ESUL AEA NAV abe RAGKAK WS 440 04S DED WSK 5, 10

Hanna v. Federal Land Bank Ass’n of Southern Illi-

nois, 903 F.2d 1159 (7th Cir. 1990)................. 10

Hess v. Port Authority Trans-Hudson Corp., 513 U.S.

i ee Soe ee ee en ee 10

In re Hoag Ranches, 846 F.2d 1225 (9th Cir. 1988) .... 10

In re Petition of Farm Credit of Western New York, et

al., Docket Nos. 816576, 816605 and 816606

(N.Y. Div. of Tax Appeals 1/13/2000) (RIA State

a ae kok Seca ub 40's wae Ads 5

Lebron v. Nat. R.R. Passenger Corp., 513 U.S. 374

ASRS RAE LENG bo ekoe Sabah Oe eek ewe hakue 10

Mayo v. United States, 319 U.S. 441 ae 11, 12

ee 1, 4, 7, 10

iv

TABLE OF AUTHORITIES - Continued

Page

National Private Truck Council v. Oklahoma, 515 U.S.

Ee CRP KS kv aes 50s 10k 0b nek rds Vas CRORE Re eR ba OREO 8

O'Melveny & Meyers v. FDIC, 512 U.S. 79 (1994)...... 7

Production Credit Association of Eastern New Mexico

v. Taxation and Revenue Department, 999 P.2d

TGSE (ERE. CE. A. Be on sc cas ca cc eesasesacdes 1

Rockford Life Insurance Co. v. Ill. Dept. of Revenue,

Oe Gh. We CUPEE 6 5 8 cn dawn an eenc snd kenesw ina ins 8

Shaw v. Gibson-Zahniser Oil Corp., 276 U.S. 575

io Pry eee e reer ree re err rere er ey Try 12

Sutth @. ULS., SOS TES. TES (IGMP ons as cece vececwceans 9

Tooke v. Miles City Production Credit Ass'n, 763 P.2d

EREE CE. TOD xo '5 6a Ki abs cece e es Weecagenesss 11

U.S. v. Haynes, 620 F.Supp. 474 (D. Tenn. 1985)...... 11

U.S. v. New Mexico, 455 U.S. 720 (1982) ............. 11

Waldschmidt v. Iowa Lakes Production Credit Ass’‘n,

SOR TU. Wee FeO CHG, BIG), ooo neve ncnvasiencnsass 10

Woodland Production Credit Ass'n v. Franchise Tax

Board, 37 Cal. Rptr. 231 (Ct. App. 1964)............ 8

STATUTES

Pep a ec omreer ype my ee ee eS 3

SS APR te sh cixanes encase’ Eres eee 3, 4, 8, 9

vik Tay 2 Se tae Te rig pret eee nis eer ye 3

i O66 SMM... 6

Vv

TABLE OF AUTHORITIES - Continued

Page

OTHER AUTHORITIES

H.R. Report No. 425, 99th Cong., 1st Sess. 11, 1985

a ME i nae RA badas Pa ended se newer dak 3

H.R. Rep. No. 593, 92nd Cong., 1st Sess. (1971),

SPER. We GE 8 xa neha es CE RRA Oa eee 2

eR | ee ret oe eee er re rer 2

Farm Credit Act of 1933, 48 Stat. 257................ 1

Farm Credit Amendments Act of 1985, 99 Stat.

SAT CAPE 605 6A 4 5s 6vE Rew Nes oe pec emer eearees 3

1 Farm Credit System Report 8 (1999) ................. 5

STATEMENT OF THE CASE

At issue in this case is whether the implied inter-

governmental tax immunity doctrine first articulated in

McCulloch v. Maryland, 17 U.S. (4 Wheat.) 316 (1819)

should prohibit the States from taxing privately-held Pro-

duction Credit Associations (“PCAs”) absent an explicit

authorization to tax, where Congress’ intent to allow such

taxation can be fairly inferred from commonly-accepted

principles of statutory construction and the legislative

history of the Farm Credit Act of 1933, 48 Stat. 257.

The New Mexico Court of Appeals correctly held that

the intergovernmental immunity doctrine should not be

applied blindly in these circumstances, and instead

looked to Congress’ intent in determining that PCAs were

not immune from state taxation. Production Credit Associa-

tion of Eastern New Mexico v. Taxation and Revenue Depart-

ment, 999 P.2d 1031 (N.M. Ct. App. 2000). This same

question (concerning “Banks for Cooperatives,” also

established by the Farm Credit Act of 1933) is currently

pending before the Court in the case of Director of Revenue

v. CoBank, ACB, No. 99-1972 (cert. granted, June 26, 2000).

Because the question presented in that case is essentially

identical to the question raised here, the Court should

stay action on this Petition until a decision is rendered

Case No. 99-1972 and deny certiorari at its conclusion, or

alternatively, accept certiorari in this case and affirm the

decision of the New Mexico Court of Appeals.

A. History of the Production Credit Associations

The Farm Credit System traces its roots to the estab-

lishment of Federal Land Banks in 1916. 39 Stat. 360

(1916). From the earliest history of the Farm Credit Sys-

tem, it is apparent that Congress carefully considered the

tax status of the various member institutions with respect

to federal, state and local taxes. Significantly, Congress

allowed the imposition of state and local property taxes

on the Federal Land Banks even while federal property

was exempt. 39 Stat. 360 (1916).

In an effort to increase the amount of capital avail-

able to farmers during the Great Depression, Congress

enacted the Farm Credit Act in 1933, creating publicly-

owned Production Credit Associations (“PCAs”) and

Banks for Cooperatives (“BFCs”). The enabling legislation

for both types of institutions provided a mechanism for

eventual private ownership, by requiring borrowers to

take stock in the lending institutions as part of any loan.

By 1968, Congress had achieved its goal of ending the

public ownership of the PCAs and the BFCs. See, H.R.

Rep. No. 593, 92nd Cong., Ist Sess. (1971), 1971

U.S.C.C.A.N. 2091, 2098.

When Congress created the PCAs, it spelled out their

tax status in considerable detail. First, Congress specified

that the PCAs and its obligations should be considered

federal instrumentalities, and as such the notes, deben-

tures and bonds of the PCAs should be exempt from

federal, state and local taxes (except estate, inheritance

and gift taxes). Congress went on to provide a broad

exemption from local, state and federal taxes (except for

property taxes on real and tangible property) so long as

the federal government held an ownership interest in the

PCAs. Once the ownership interest ended, the states were

free to tax the PCAs on the same basis as other for-profit

ventures. The Banks for Cooperatives were subject to the

same conditional exemption. 48 Stat. 257, 267. The condi-

tional tax exempt status of these two institutions should

be contrasted with the tax exemption provided to two

other lending institutions created by the Farm Credit Act

of 1933, Farm Credit Banks (12 U.S.C. § 2023), and Fed-

eral Land Bank Associations (12 U.S.C. § 2098). Those

institutions were provided with a broad exemption from

all taxation except property taxes on real and personal

property.

In 1971 the Farm Credit Act was substantially

amended, but the differing tax treatment afforded to the

component entities of the Farm Credit System remained

unchanged.

In 1985, Congress made significant changes in the

Farm Credit System in response to an on-going farm

crisis. Farm Credit Amendments Act of 1985, 99 Stat.

1703-1707 (1985). A major objective of the legislation was

to reduce the involvement of the Farm Credit Administra-

tion in the day-to-day operations of the member institu-

tions of the Farm Credit System, and to strengthen its role

as a regulator of the institutions. H.R. Report No. 425,

99th Cong., 1st Sess. 11, 1985 U.S.C.C.A.N. 2587. One

piece of that legislation was a “technical and conforming”

amendment which struck numerous outmoded references

to the “Governor of the Farm Credit Administration” and

which amended 12 U.S.C. § 2077 to eliminate both the

PCAs’ statutory exemption from tax and that exemption’s

conditional phase-out provision for publicly-owned

PCAs. Because the stock of all PCAs had been privately

held since 1968, both the exemption and its phase-out

provision were now surplusage. The exception had long-

since swallowed the rule.

B. The Decision Below

The New Mexico Court of Appeals held that PCAs

were instrumentalities of the United States, and were

therefore entitled to implied immunity from state and

local taxation unless the same had been waived. Petition

pp. 6a-7a. The court went on to hold that the provisions

of 12 U.S.C. § 2077 were ambiguous in light of the express

language contained in the 1933 and 1971 Farm Credit

Acts where Congress expressed its intent to subject pri-

vately-held PCAs to state and local taxation. Id. at 9a-10a.

The court concluded that Congress’ intent in eliminating

the last two sentences in 12 U.S.C. § 2077 was simply to

eliminate surplus language, since all PCAs had been pri-

vately held since 1968. The court also found that the

legislative history of Pub. L. 99-205, indicating Congress

intended to make only “technical and conforming”

amendments to the 12 U.S.C. § 2077, coupled with the

_ absence of any mention of reversing a fifty-year policy of

allowing state taxation in House Report No. 425, negated

any inference that Congress intended to reinstitute state

tax immunity. Id. at 1la-12a. Most significantly, the court

below concluded that McCulloch should apply only when

Congress has been silent on the issue of state taxation;

where Congress has spoken, it is up to the courts to

ascertain Congress’ intent. Id. at 13a. The court concluded

that Congress has “unequivocally evinced its unwavering

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intention to subject privately owned credit associations to.

state income taxation.” Id. at 14a.

C. Misstatements of Fact

Petitioner warns that if the decision below stands it

will have “serious negative implications” for the financial

condition of not just the PCAs, but also for farmers and

ranchers who rely on them for loans. Petition, p. 10.

There is no foundation for this claim in the record. No

evidence has been tendered that the PCAs are in any

financial peril.! The argument is counter-intuitive at best,

since the income taxes at issue here are imposed only on

net profits. The PCAs could reduce or eliminate any state

income tax liability simply by lowering the interest rates

they charge to the farmers and ranchers who borrow

from them. Petitioner further warns (Petition, p. 11) of

the potential for “very large retroactive tax liabilities” if

the decision below is not reversed. That claim is also

highly speculative. The Petitioner in this case, as in other

reported PCA cases, seeks a refund of taxes previously

paid. See, e.g, Farm Credit Serv. of Mid-America v. Depart-

ment of State Revenue, 705 N.E. 2d 1089 (Ind. Tx. Ct. 1999);

In re Petition of Farm Credit of Western New York, et al.,

1 The 1998 Report on the Financial Condition and Performance

of the Farm Credit System published by the Farm Credit

Administration notes that the member institutions of the Farm

Credit System “continued to reflect strong financial

performance, particularly in earnings and growth.” The Direct

Lender Associations (PCAs, Agricultural Credit Associations

and Federal Land Credit Associations) reported net income of

$704 million, up from $521 million in 1994. 1 Farm Credit System

Report 8, 29 (1999).

Docket Nos. 816576, 816605 and 816606 (N.Y. Div. of Tax

Appeals 1/13/2000) (RIA State and Local Taxes).

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REASONS FOR DENYING THE WRIT

A.

CERTIORARI SHOULD NOT BE GRANTED WHERE

THE SAME QUESTION IS CURRENTLY BEFORE THE

COURT

Certiorari should not be granted in this case because

the same issues are currently before the Court in Director

of Revenue v. CoBank, ACB, No. 99-1972 (cert. granted,

6/26/00). The resolution of that case should be disposi-

tive of the question presented here where: (a) the tax

immunity afforded to Banks for Cooperatives, 12 U.S.C.

§ 2134, is identical to the immunity provided for PCAs, 12

U.S.C. § 2077; (b) the legislative history of the two stat-

utes is identical, and (c) the PCAs and the Banks for

Cooperatives share a common purpose, structure and

relationship to the federal government. Further review of

the question presented here for PCAs should be unneces-

sary. Alternatively, the Court should stay action on this

Petition until a decision is rendered in Cause No. 99-1972,

at which time certiorari should be granted for the pur-

pose of affirming the decision of the court below.

CERTIORARI SHOULD NOT BE GRANTED WHERE

THE COURT BELOW CORRECTLY DETERMINED

THAT CONGRESS’ INTENT TO SUBJECT PCAs TO

STATE INCOME TAX WAS CLEAR, OBVIATING THE

NEED FOR IMPLYING AN IMMUNITY UNDER

McCULLOCH v. MARYLAND

The court below correctly held that Congress had

expressed its intention to allow state taxation of pri-

vately-held PCAs, eliminating any need to apply a sepa-

rate implied immunity analysis under McCulloch v.

Maryland. Petition, p. 13a. Because the decision of the

New Mexico Court of Appeals is correct in its reasoning

and result, certiorari is unnecessary.

1. Where a Limited Immunity is Established

by Statute, No Broader Immunity Should

Ordinarily be Implied

Because Congress has explicitly addressed the ques-

tion of how much immunity should be provided to PCAs,

this Court should assume, in the absence of evidence to

the contrary, that Congress intended to afford just that

much immunity from taxation and no more. “[Mlatters

left unaddressed in such a scheme are presumably left

subject to the disposition provided by state law.”

O'Melveny & Meyers v. FDIC, 512 U.S. 79, 85 (1994).

“Inclusio unius, exclusio alterius. . . . To create additional

‘federal common law’ exceptions is not to ‘supplement’

this scheme, but to alter it.” Id. at 86-87.

The principle that additional preemption should not

be inferred where Congress has spoken has particular

application to state taxation. See, Department of Revenue of

Oregon v. ACF Industries, Inc., et al., 510 U.S. 332, 345

(1994) (“When determining the breadth of a federal stat-

ute which impinges upon or pre-empts the States’ tradi-

tional powers, we are hesitant to extend the statute

beyond its evident scope.”); Rockford Life Insurance Co. v.

Ill. Dept. of Revenue, 482 U.S. 182, 191 (1987) (“A court

must proceed carefully when asked to recognize an

exemption from taxation that Congress has not clearly

established.”). See also, National Private Truck Council v.

Oklahoma, 515 U.S. 582 (1995) (federal statutes are con-

strued against the background presumption of non-inter-

ference with state taxation).

In the present case, Congress’ intent to allow state

taxation is evident not only from the express preemption

in 12 U.S.C. § 2077, which is limited to taxation of bonds,

notes and debentures, but from the history of that statute

and the background of the PCAs as well. From their

inception, the PCAs (and Banks for Cooperatives) were

never afforded the degree of immunity afforded the Fed-

eral Land Banks and other components of the Farm

Credit System. The broad immunity from state taxation,

in the (repealed) second sentence of § 2077, which was

provided to the PCAs was always contingent on a federal

ownership interest. The (repealed) third sentence of

§ 2077 phased out the broad exemption upon PCAs’

becoming privately owned. When both the contingency

and the exemption were removed in 1985, Congress was

presumably aware that privately-held PCAs had been

held subject to state taxation, see, e.g., Woodland Production

Credit Ass'n v. Franchise Tax Board, 37 Cal. Rptr. 231, 233

(Ct. App. 1964), yet Congress did not retain the broad

exemption from tax in the second sentence of § 2077,

which would have re-established immunity for the pri-

vately-held PCAs. The contemporaneous record of the

1985 legislative changes indicates Congress intended to

make only “technical and conforming” changes to the

statute, not a reversal of fifty years of tax policy. Finally,

the explicit income tax exemption which Congress pro-

vided to Farm Credit Banks and Federal Land Bank Asso-

ciations removes any doubt as to what Congress

intended. Smith v. U.S., 508 U.S. 223, 233 (1993) (“Just as a

single word cannot be read in isolation, nor can a singie

provision of a statute.”). The court below correctly relied

on this overwhelming evidence of congressional intent to

conclude that there was no room to engraft a doctrine of

implied immunity under the Supremacy Clause to reach a

contrary result.

2. PCAs Are Not So Closely Connected to the

Federal Government as te Require a Pre-

sumption of Immunity from State Taxation.

In Arkansas v. Farm Credit Services of Central Arkansas,

520 U.S. 821 (1997), this Court ruled that PCAs were not

sufficiently close to the federal government to fall within

the exception from the Tax Injunction Act afforded to the

federal government. “An instrumentality of the United

States can enjoy the benefits and immunities conferred by

explicit statutes, however, without the further inference

that the instrumentality has all of the rights and privi-

leges of the National Government.” Id., at 829 (emphasis

added). After listing the various tests employed by the

courts for determining whether a particular entity may

sue to enjoin state taxes in federal court, this Court held

10

that the PCAs met none of them. Id., at 831. The PCAs’

business purpose was making commercial loans, they

were privately-owned, and they did not exercise powers

analogous to federal departments or regulatory agencies.

Id. at 831-32. There is no reason to adopt a different

analysis when determining whether the PCAs should

now enjoy an implied, constitutional immunity from tax-

ation under McCulloch.

The result in Farm Credit Services is consonant with

the established rule that courts are not bound by statu-

tory labels when discerning the constitutional rights or

obligations of the government. See, e.g., Lebron v. Nat. R.R.

Passenger Corp., 513 U.S. 374 (1995) (Amtrak an arm of the

government for the purposes of the First Amendment

despite its statutory designation-as a private corporation);

Andrews v. Federal Home Land Bank of Atlanta, 998 F.2d 214

(4th Cir. 1993) (Federal Land Bank not an arm of the

government for the purposes of the First Amendment

despite its statutory designation as an instrumentality of

the United States). See also, Hess v. Port Authority Trans-

Hudson Corp., 513 U.S. 30, 44-45 (1994) (for purposes of

Eleventh Amendment immunity, statutory characteriza-

tion of entity is only one factor in analysis).

With regard to PCAs in particular, the courts have

generally treated them like private parties, and not the

government, on a host of issues. Hanna v. Federal Land

Bank Ass‘n of Southern Illinois, 903 F.2d 1159 (7th Cir. 1990)

(PCAs subject to jury trials); In re Hoag Ranches, 846 F.2d

1225 (9th Cir. 1988) (PCAs are not afforded the govern-

ment’s extended period of time to file a notice of appeal);

Waldschmidt v. Iowa Lakes Production Credit Ass'n, 380

N.W.2d 704 (Iowa, 1986) (PCAs are not protected by the

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Federal Tort Claims Act); Tooke v. Miles City Production

Credit Ass'n, 763 P.2d 1111 (Mont. 1988) (same); U.S. v.

Haynes, 620 F.Supp. 474 (D. Tenn. 1985) (indictment

against PCA employee for engaging in a conflict of inter-

est with the federal government dismissed because PCA

was not the federal government).

The concept that instrumentalities like the PCAs

should not automatically be treated as the federal govern-

ment itself is reflected in this Court’s modern inter-

governmental immunity cases. Both explicitly and

implcitly, the Court has drawn a distinction between state

taxes imposed directly upon the United States, for which

an express waiver of immunity has been required, Cotton

Petroleum Corp. v. New Mexico, 490 U.S. 163, 175 (1989),

and taxes imposed on federal instrumentalities. In the

latter situation, this Court has looked to the content of the

legislation creating the instrumentality and the nature

and governmental purpose of that instrumentality. U.S. v.

New Mexico, 455 U.S. 720, 735 (1982) (“[T]ax immunity is

appropriate in only one circumstance: when the levy falls

on the United States itself, or on an agency or instru-

mentality so closely connected to the Government that

the two cannot realistically be viewed as separate entities,

at least insofar as the activity being taxed is concerned.”).

The Petitioner cites Mayo v. United States, 319 U.S. 441

(1943) to support its contention that immunity for instru-

mentalities is automatic. The holding in Mayo does not

conflict with the decision below; in fact Mayo supports it.

In Mayo, the United States Department of Agriculture

was subject to a direct tax upon its property. In striking

down the tax, this Court drew a distinction between state

taxes laid directly upon the government, for which

12

express consent was required, and taxes laid upon federal

instrumentalities, for which it was appropriate to con-

sider the context of the legislation and purpose of the

instrumentality:

The silence of Congress as to the subjection

of its instrumentalities, other than the United

States, to local taxation or regulation is to be

interpreted in the setting of the applicable legis-

lation and the particular exaction. [citation omit-

ted] But where, as here, the governmental action

is carried out by the United States itself and

Congress does not affirmatively declare its

instrumentalities or property subject to regula-

tion or taxation, the inherent freedom continues.

319 U.S. at 447-48. (emphasis added).

The case of Shaw v. Gibson-Zahniser Oil Corp., 276 U.S.

575 (1928) cited by the Mayo Court is also instructive. In

holding that the Secretary of Interior lacked the implied

authority to confer immunity from state royalty taxes on

land purchased for Indians from Indian trust money, this

Court wrote: “What Government instrumentalities will be

held free from state taxation, though Congress has not

expressly so provided, cannot be determined apart from

the purpose and character of the legislation creating

them.” 276 U.S. at 578.

In the present case, Congress has specified that the

PCAs are instrumentalities of the federal government, but

it does not follow that the PCAs are the government

itself. They are hybrid creatures at best, performing some

limited functions which government might otherwise

carry out, but organized for private profit. There is no

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compelling reason why an immunity from taxation must

be inferred for such entities.

.

CONCLUSION

For the reasons set forth above, Respondent prays for

an order denying certiorari in this case, or alternatively,

for an order granting certiorari and affirming the decision

of the New Mexico Court of Appeals.

Respectfully submitted,

Patricia MaAprRID

Attorney General of New Mexico

Dona_p F. Harris

Counsel of Record

Bruce J. Fort

Special Assistant Attorneys

General

New Mexico Taxation

and Revenue Department

P.O. Box 630

Santa Fe, New Mexico 87509

(505) 841-6583