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BRUNSWICK CORP. v. TAX. DIV. DIR.

11 N.J. Tax 530 (1991)

BRUNSWICK CORP., PLAINTIFF, v. DIRECTOR, DIV. OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

May 21, 1991.

Attorney(s) appearing for the Case

Charles M. Costenbader for plaintiff (Stryker, Tams & Dill, attorneys; Paul M. Frankel of counsel; Charles H. Friedrich on the brief).

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

LASSER, P.J.T.C.

Taxpayer contests deficiency tax assessments, interest and penalties imposed by the Director of the Division of Taxation (Director) with regard to taxpayer's 1986 and 1987 corporation business tax (CBT) returns. The deficiency assessments result from the Director's modification of the allocation factor used by taxpayer to calculate the portion of its income attributable to New Jersey under the New Jersey Corporation Business Tax Act (CBT Act),

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