Current through Register Vol. 35, No. 18, September 24, 2024
A.
COMMUNICATIONS SYSTEMS - MICROWAVE TRANSMISSION: Property that is
used in the conduct of the communications business includes all property that
is a part of a communications system, including, but not limited to, property
which is used for purposes of microwave transmission or reception. It does not
include the installation, operation or maintenance of microwave property
incidental to the operation and conduct of radio and television broadcasting
stations licensed by the federal communications commission, except when
microwave transmission or reception is separately sold during the regular
course of business, or when a two-way communication link is established and
service provided by the link is sold to another person during the regular
course of business, such as two-way cable television communications
linkage.
B.
COMMUNICATIONS
SYSTEMS - VALUATION OF PROPERTY NOT "PLANT": If property does not fall
within the definition of "plant", "construction work in progress" or "materials
and supplies" as defined in Paragraphs (4), (5) and (7) of Subsection B of
Section
7-36-30
NMSA 1978, then that property is valued pursuant to Section
7-36-15
NMSA 1978 and regulations thereunder.
C.
COMMUNICATIONS SYSTEMS -
DEPRECIATION AND TANGIBLE PROPERTY COSTS:
(1) For purposes of calculating depreciation
or related accumulated provision for depreciation, straight line depreciation
over the useful life of the item of property, as defined by federal or state
regulatory agencies having jurisdiction, is used.
(2) If property does not fall under federal
or state regulatory agency authority, the division establishes the useful life
of said property in accordance with its class life under Section 167 of the
Internal Revenue Code and regulations thereunder. The tangible property costs
of the portion of the plant comprising land shall be the total actual costs of
acquisition of the land as of January 1 of the tax year in which the property
is valued.
D.
COMMUNICATIONS SYSTEMS - CONSTRUCTION WORK IN PROGRESS: those
persons who maintain their records in accordance with a uniform system of
accounts approved by a state or federal regulatory agency may use the amounts
entered on those accounts as construction work in progress as of December 31 of
the preceding calendar year as the value of construction work in progress,
provided that the account is limited to work orders for "plant" as defined in
Paragraph (4) of Subsection B of Section
7-36-30
NMSA 1978, and regulations thereunder. Land and land rights included in
construction work in progress accounts must be reported at the actual cost of
acquisition as of January 1 of the tax year in which the property is
valued.
E.
COMMUNICATIONS
SYSTEMS - VALUATION METHOD:
(1)
Communications systems property may be valued by applying the unit rule of
appraisal at the election of a taxpayer. The unit rule of appraisal is,
generally, an appraisal of an integrated property as a whole without reference
to the value of its component parts. At the election of a taxpayer, the unit
rule of appraisal may be applied using the approaches to value set out in
Section 3.6.5.37 NMAC.
(2)
Capitalization of Earnings - Capitalization of earnings value is computed as
follows: the net operating income derived from the operations of the
communications business in all states is divided by a capitalization rate
determined for the particular company being valued. The capitalization rate
will be determined by the division using the band of investment method, or any
other method that is consistent with generally accepted appraisal techniques.
The quotient resulting from this division is the capitalized earnings value of
the communications business. "Net operating income" as that phrase is used in
the first sentence of this paragraph means the expected future gross income of
the business from operations after deduction of the operating costs of the
business, including taxes and depreciation directly relating to the business.
Net operating income is determined after an analysis of the preceding five
years' net operating income. In determining net operating income, reference is
made to reports which the business is required to make to federal and state
regulatory agencies and taxing agencies. The division is not bound, however, by
the income information shown on these reports in determining net operating
income and may use information acquired from other sources. Net operating
income may be adjusted to reflect future earnings ability of construction work
in progress.
(3) Market Value of
Stock and Debt - Market value of stock and debt is computed as follows:
(a) The market value of all the stock of the
business is computed on the basis of the average of the monthly high and low
market prices quoted in financial publications for the preceding tax year. If
stock of the business is not traded or is not traded in sufficient volume to
indicate value, the division may rely on a price earnings ratio, or other
methods consistent with generally accepted appraisal techniques to determine
the market value of the stock.
(b)
The market value of the business' debt and other obligations is determined on
the basis of the published quotations for each of the various types of
obligations and current liabilities as reflected on the books and records of
the business.
(c) The total of the
market value of the stock as computed under Subparagraph (a) of this paragraph
and the market value of debt and other obligations as computed under
Subparagraph (b) of this paragraph produces the total system value of all the
communications business property, both tangible and intangible. From this total
system value, there is subtracted the value of non-communications property
which is not used by the communications company in its communications
operations, and the value of intangible property used in its operations. To
this net total system value, there is added the value of all leased equipment
to produce the total stock and debt value.
(4) Cost less Depreciation and Obsolescence -
Cost less depreciation and obsolescence is computed as follows:
(a) The cost of all communications plant in
service in all states, less depreciation and amortization as of January 1 of
the tax year as reported to the federal communications commission of the United
States or other state or federal regulatory agencies having jurisdiction;
plus
(b) The cost of all materials
and supplies in all states as of January 1 of the tax year; plus
(c) Fifty percent (50%) of the cost or amount
expended for "construction work in progress" in all states on January 1 of the
tax year, as reported to the federal communications commission, or other state
or federal regulatory agencies having jurisdiction. advance payments for work
not partially completed or not commenced on January 1 of the tax year, however,
may be excluded at one hundred percent (100%) upon a proper showing by the
taxpayer.
(d) A deduction for
functional or economic obsolescence may, upon presentation of substantial
evidence and documentation, be made from the total of the cost computed under
Subparagraph (a) of this paragraph.
(e) Functional obsolescence is the loss in
value due to functional inadequacies or deficiencies caused by factors within
the property.
(f) Economic
obsolescence is the loss in value caused by unfavorable economic influences or
factors outside the property.
(g)
Requests for economic or functional obsolescence adjustments to the cost
approach must be made at the time the annual report is filed. The request must
be supported with sufficient documentation, and must be based on a situation
present at least six (6) months prior to January 1 of the tax year. An economic
or functional obsolescence factor must be provided, together with documentation
to support and demonstrate how the factor was arrived at. Such documentation
shall consist of objective evidence supporting functional or economic
obsolescence. Failure to provide enough documentation or proof shall result in
denial of an obsolescence adjustment.
(5) The division considers the values
computed under the three evidences of value referred to in Paragraphs (2), (3)
and (4) of this subsection and, either:
(a)
assigns weights, in terms of percentage to each evidence of value, with a total
of 100%, on the basis of the evidence which appear to be most indicative of
market value, multiplies the values determined under the three evidences of
value by the respective weights and adds the three totals to give the total
system value of all property used in the conduct of the communications
business; or
(b) correlates the
values computed under the three evidences of value to determine the total
system value of all property used in the conduct of the communications
business.
(6) The total
system value of all property used in the conduct of the communications business
in all states is allocated to New Mexico by multiplying this total value by
fractions, the numerators of which are the total gross investment, gross
operating revenues, wire miles, and number of access lines of the
communications company in New Mexico and the respective denominators of which
are the total gross investment, gross operating revenues, wire miles, and
number of access lines of the communications company in all states. The
products of the multiplication by each of these fractions is considered by the
division in determining the proper allocation of the total system value to New
Mexico. Use of other factors to compute allocation of the total system value to
New Mexico or elimination of one or more of the required factors from
consideration may be permitted by order of the director upon good cause shown.
The correlated product of the multiplication of the total system value in all
states by the fractions is New Mexico's allocated portion of property used in
the conduct of the communications business and is the value for property
taxation purposes of the communications property used in the conduct of the
communications business in New Mexico.
F.
COMMUNICATIONS SYSTEMS - ALLOCATIONS
OF VALUE WITHIN NEW MEXICO:
(1)
Distribution of the value of all communications system property allocated to
New Mexico which is valued by the division is accomplished in the following
manner:
(a) An equitable portion of the total
unit value allocated to New Mexico is computed and distributed to the specific
governmental unit or units wherein are located sizeable facilities, such as
offices, shops, and other special facilities.
(b) The value computed under Subparagraph (a)
of this paragraph is deducted from the total value as determined under Section
3.6.5.37 NMAC, and the remainder is distributed to the governmental unit or
units in which the property is located on the basis of the proportion of wire
miles and number of access lines in the governmental unit or units compared to
the total of wire miles and number of access lines in New Mexico
respectively.
(c) The division may
vary the distribution methods described in Subparagraphs (a) and (b) of this
paragraph to account for unusual or substantial changes in the operations or
gross investment of the company within the governmental units.
(2) "Gross investment" as that
phrase is used in Section 3.6.5.37 NMAC means the original cost, without
deductions of any kind, of all kinds of property used in the conduct of
communications business. Reference shall be made to reports made to federal or
state regulatory agencies having jurisdiction in determining gross
investment.