LARIO, J.T.C.
Defendant, Director, Division of Taxation, has moved for summary judgment dismissing plaintiff's complaint appealing the determination of the Director that plaintiff was not entitled to an abatement of interest and penalties imposed upon plaintiff by the Director. Defendant's motion is predicated upon its claim that the complaint, which was filed on August 17, 1990, was filed more than 90 days after the date which it alleges that its final determination...
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