LARIO, J.T.C.
Wheaton Industries appeals from part of a final determination of the Director, Division of Taxation, assessing it a balance of tax liability under the New Jersey Sales and Use Tax Act, N.J.S.A. 54:32B-1, et seq. [the act] for the period April 1, 1983 to June 30, 1987.
The issue presented by the challenged portion is whether a tax under the act applies to labor charges made by an out-of-state contractor for reconditioning plaintiff...
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