MILLER v. DIRECTOR, DIV. OF TAXATION


19 N.J. Tax 522 (2001)

GEORGE K. MILLER, JR. AND DEBRA MILLER, PLAINTIFFS, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

August 20, 2001.


Attorney(s) appearing for the Case

Daniel J. Gallagher, for plaintiffs (George K. Miller, Jr., attorney).

Mala Narayanan, for defendant (John J. Farmer, Jr., Attorney General of New Jersey, attorney).


SMALL, P.J.T.C.

This is another in a series of cases dealing with the characterization of income for New Jersey Gross Income Tax purposes as it is passed through from a "pass-through entity" (e.g., a partnership or subchapter S corporation) to an individual taxpayer. See Koch v. Director, Div. of Taxation, 157 N.J. 1, 722 A.2d 918 (1999); Smith v. Director, Div. of Taxation,

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