KAHN, J.T.C.
Plaintiff contests the validity of assessments imposed by defendant pursuant to the Corporation Business Tax Act, N.J.S.A. 54:10A-1 et seq. Plaintiff contends that it is a financial business corporation and therefore entitled to deduct 100% of interest expenses relating to its indebtedness to an affiliated corporation in accordance with N.J.S.A. 54:10A-4(d) and -4(k)(2)(E)(iii). The Division of Taxation disagreed and imposed taxes...
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