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AVCO FINANCIAL SERV. CONSUMER DISCOUNT CO. ONE, INC. v. DIR. TAX DIV.

193 N.J. Super. 503 (1984)

475 A.2d 66

AVCO FINANCIAL SERVICES CONSUMER DISCOUNT CO. ONE, INC., PLAINTIFF-RESPONDENT, v. DIRECTOR, DIV. OF TAXATION, DEFENDANT-APPELLANT.

Superior Court of New Jersey, Appellate Division.

Decided February 27, 1984.

Attorney(s) appearing for the Case

Martin L. Wheelwright, Deputy Attorney General argued the cause for appellant (Irwin I. Kimmelman, Attorney General of New Jersey, attorney; James J. Ciancia, of counsel and Martin L. Wheelwright, on the brief).

Alvin Weiss argued the cause for respondent (Riker, Danzig, Scherer & Hyland, attorneys; Marie L. Garibaldi, Jacqueline Robinson Drakeford and J. Ferd Convery, III, on the brief).

Before Judges MICHELS, KING and DREIER.

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

The Director of the Division of Taxation has appealed from an adverse determination by the Tax Court, reported at 4 N.J.Tax 349 (1982), thwarting the defendant's efforts to tax the income received by plaintiff from loans made through its Pennsylvania offices to New Jersey residents. This case requires an analysis of the Corporate Income Tax Act, N.J.S.A. 54:10E-1...

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