REUBEN H. DONNELLEY CORP. v. DEPT. OF TREASURY, DIV. OF TAXATION


11 N.J. Tax 241 (1990)

THE REUBEN H. DONNELLEY CORPORATION, PLAINTIFF, v. THE NEW JERSEY DEPARTMENT OF THE TREASURY, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

August 17, 1990.


Attorney(s) appearing for the Case

Charles M. Costenbader (Stryker, Tams & Dill, attorneys) and Jerome R. Hellerstein, admitted pro hac vice, (Herzfeld & Rubin, attorneys) for plaintiff.

Margaret A. Holland for defendant (Robert J. Del Tufo, Attorney General of New Jersey, attorney).


ANDREW, J.T.C.

In this state tax case plaintiff, The Reuben H. Donnelley Corporation, seeks review of a decision of the Director, Division of Taxation revising the property fraction of plaintiff's business allocation factor for purposes of the Corporation Business Tax Act (CBT), N.J.S.A. 54:10A-1 et seq., for the tax years of 1983 and 1984.

Specifically, plaintiff maintains that the Director's determination to exclude plaintiff's "safe harbor...

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