OFF v. DIV. OF TAXATION FOR THE STATE


16 N.J. Tax 157 (1996)

LOUIS B. OFF, EXECUTOR OF THE ESTATE OF LOIS ECKEL, PLAINTIFF, v. DIVISION OF TAXATION FOR THE STATE OF NEW JERSEY AND TRANSFER INHERITANCE TAX BUREAU, DEFENDANT.

Tax Court of New Jersey

Decided July 17, 1996.


Attorney(s) appearing for the Case

Theodore S. Ridgway, Linwood, for plaintiff (Ridgway and Ridgway, attorneys).

Paul Tannenbaum, Trenton, for defendant (Deborah T. Poritz, Attorney General of the State of New Jersey, attorney).


RIMM, J.T.C.

This is a transfer inheritance tax matter in which the Director, Division of Taxation, moves for summary judgment. The Director contends that the complaint must be dismissed under N.J.S.A. 54:34-13 and N.J.S.A. 54:49-18(a) because plaintiff neither protested the Director's assessment nor filed a complaint in the Tax Court to challenge the assessment within ninety days of the date the assessment was made.

I

The decedent...

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