CRABTREE, J.T.C.
Plaintiff seeks review of defendant's determination that the sum of $56,000,000 owed by plaintiff to an affiliated corporation as of December 31, 1974 must be included in plaintiff's net worth and 90% of the interest paid thereon disallowed for calendar year 1974 for purposes of the Corporation Business Tax Act, N.J.S.A. 54:10A-1 et seq. The effect of defendant's determination is to deny plaintiff's refund claim for $68,826.77.
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