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HESS REALTY CORP. v. TAXATION DIV. DIRECTOR

10 N.J. Tax 63 (1988)

HESS REALTY CORPORATION, PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, NEW JERSEY DEPARTMENT OF TREASURY, DEFENDANT.

Tax Court of New Jersey.

July 14, 1988.

Attorney(s) appearing for the Case

Christine D. Petruzzell for plaintiff (Wilentz, Goldman & Spitzer, attorneys; Christine D. Petruzzell and Viola S. Lordi on the brief).

Carolyn L. Lurry for defendant (W. Cary Edwards, Attorney General of New Jersey, attorney).

ANDREW, J.T.C.

In this state tax case plaintiff, Hess Realty Corporation (HRC), seeks review of a determination by the Director of the Division of Taxation (Director) revising HRC's "business allocation factor" for purposes of its corporation business taxes for the tax years 1981 and 1982 pursuant to the Corporation Business Tax Act (CBT), N.J.S.A. 54:10A-1 to -40. HRC argues that the Director's determination does not accurately reflect its business activity...

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