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TUITION PLAN OF NEW HAMPSHIRE v. TAXATION DIV. DIR.

4 N.J. Tax 470 (1982)

THE TUITION PLAN OF NEW HAMPSHIRE, PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

July 28, 1982.

Attorney(s) appearing for the Case

Marie L. Garibaldi for plaintiff (Riker, Danzig, Scherer & Hyland, attorneys).

Martin L. Wheelwright for defendant (Irwin I. Kimmelman, Attorney General of New Jersey, attorney).

CRABTREE, J.T.C.

Plaintiff seeks review of defendant's determination that plaintiff is subject to the New Jersey Corporation Income Tax Act, N.J.S.A. 54:10E-1 et seq. for the calendar years 1974 through 1977. The determination is based upon income attributable to loans made by plaintiff to New Jersey residents. Plaintiff claims that the determination and any tax assessed pursuant thereto violate the Due Process...

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