ANDREW, J.T.C.
In this state tax action, plaintiff Chemical Realty Corp. challenges an assessment made by defendant Director, Division of Taxation under the Corporation Income Tax Act, N.J.S.A. 54:10E-1 et seq., for the taxable year ending December 31, 1974. Although a number of questions have been presented, the primary issue is whether New Jersey has jurisdiction to tax plaintiff's interest and other income from loans secured by New Jersey realty....
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