CRABTREE, J.T.C.
Plaintiff challenges assessments imposed by defendant pursuant to the New Jersey Corporation Income Tax Act, N.J.S.A. 54:10E-1 et seq., in the amounts of $1,308.99 for fiscal year ended November 30, 1974 and $2,123.46 for fiscal year ended November 30, 1975. The assessments are based upon income attributable to loans made by plaintiff to New Jersey residents.
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