The department audited taxpayer's business for the years 1982-85. At the formal hearing reviewing the assessment, both parties agreed that there was only one issue to be heard: whether taxpayer's disposal of a pawnor's chattel was subject to taxation pursuant to NMSA 1978, Section 7-9-4 (Cum. Supp. 1981 and Repl. Pamp. 1983), which was applicable during the audited period.
