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CORPORATE PROPERTY INVESTORS v. DIRECTOR, DIVISION OF TAXATION

15 N.J. Tax 14 (1994)

CORPORATE PROPERTY INVESTORS, PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

April 20, 1994.

Attorney(s) appearing for the Case

Michael A. Guariglia for plaintiff (McCarter & English, attorneys; Susan A. Feeney and John K. Bradley, on the brief).

Joseph Fogelson for defendant (Robert J. DelTufo, Attorney General of New Jersey, attorney).

CRABTREE, J.T.C.

Plaintiff seeks review of defendant's determinations denying plaintiff's claims for refunds of New Jersey corporation business tax (CBT) for 1987, 1988 and 1989 aggregating $722,543 and assessing additional CBT of $534,798, plus interest and penalty for the years 1985 through 1989. Both parties have moved for summary judgment and, as there are no material facts in dispute, the case is ripe for adjudication.

The only issues remaining are (1...

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