The opinion of the court was delivered by LINTNER, J.A.D.
The Director of the Division of Taxation (Director or Division) appeals the Tax Court's reversal of a Corporation Business Tax (CBT) Act, N.J.S.A. 54:10A-1 to -41, assessment against Clorox Products Manufacturing Company (Taxpayer) in the amount of $84,924.43 for the years 1998, 1999, and 2000, including a five
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