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WALSH v. DIRECTOR, DIV. OF TAXATION

15 N.J. Tax 180 (1995)

FRANK E. WALSH, JR., AND MARY D. WALSH, PLAINTIFFS-APPELLANTS, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-RESPONDENT.

Superior Court of New Jersey, Appellate Division.

Decided April 19, 1995.

Attorney(s) appearing for the Case

Robert J. Alter argued the cause for appellant (Sills, Cummis, Zuckerman, Radin, Tischman, Epstein & Gross, attorneys; Mr. Alter, of counsel; Mr. Alter and James M. Hirschhorn, on the brief).

Margaret A. Holland, Deputy Attorney General, argued the cause for respondent (Deborah T. Poritz, Attorney General of New Jersey, attorney; Joseph L. Yannotti, Assistant Attorney General, of counsel; Ms. Holland, on the brief).

Before Judges VILLANUEVA, WEFING and BRAITHWAITE.

PER CURIAM.

Plaintiffs, Frank E. Walsh, Jr. and Mary D. Walsh, appeal from a Tax Court judgment which affirmed the Director, Division of Taxation's disallowance of their deduction for a nonbusiness bad debt on their 1987 State income tax returns. Plaintiffs contend that although the New Jersey Gross Income Tax Act does not explicitly provide for a bad debt deduction, such a deduction is implicitly included in N.J.S.A. 54A:5-1c which allows the deduction of...

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