Because the sale of commercial paper in itself is not subject to the gross receipts tax and because receipts from underlying transactions are exempt under Section 7-9-22.1 NMSA 1978, receipts from the sale of financing agreements to a bank or a financial corporation with respect to the sale of a boat subject to taxation under Section 66-12-6.1 NMSA 1978 are also exempt.
N.M. Admin. Code § 3.2.110.9