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SMZ CORP. v. TAXATION DIV. DIRECTOR

193 N.J. Super. 305 (1984)

473 A.2d 982

S.M.Z. CORPORATION, PLAINTIFF-APPELLANT, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-RESPONDENT.

Superior Court of New Jersey, Appellate Division.

Decided January 11, 1984.

Attorney(s) appearing for the Case

Steven R. Irwin argued the cause for appellant (Mandelbaum & Mandelbaum, attorneys; Steven R. Irwin, on brief).

Harley A. Williams, Deputy Attorney General, argued the cause for respondent (Irwin I. Kimmelman, Attorney General, attorney; James J. Ciancia, Assistant Attorney General, of counsel; Harley A. Williams on brief).

Before Judges ARD, MORTON I. GREENBERG and TRAUTWEIN.

The opinion of the court was delivered by ARD, P.J.A.D.

This is a tax case involving the New Jersey Corporation Business Tax Act, N.J.S.A. 54:10A-1 et seq. Specifically, we are called upon to interpret N.J.S.A. 54:10A-6 and 8 and the administrative code definitions and regulations implementing these sections.

The factual complex is not in dispute. The S.M.Z. Corporation (S.M.Z.) is incorporated under the laws of New Jersey and maintains...

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