The purpose of the deduction of receipts from the sale of fuel loaded or used by a common carrier in a locomotive engine from gross receipts and of the deduction of the value of fuel to be loaded or used by a common carrier in a locomotive engine in computing the compensating tax is to encourage the construction, renovation, maintenance and operation of railroad locomotive refueling facilities and related activities in New Mexico.
N.M. Admin. Code § 3.2.250.6