ESTATE OF PELLIGRA v. DIR. OF TAXATION


23 N.J. Tax 658 (2008)

ESTATE OF JOSEPHINE PELLIGRA, GERALD G. SCHWEIGHART, SR., EXECUTOR, PLAINTIFFS v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

February 20, 2008.


Attorney(s) appearing for the Case

Lawrence B. Diener, for plaintiff.

Michael J. Spina, for defendant (Anne Milgram, Attorney General of New Jersey, attorney).


PIZZUTO, J.T.C.

This case presents the question of whether the ninety-day period allowed by N.J.S.A. 54:49-18 a for the filing of an administrative protest of an additional transfer inheritance tax assessment begins to run as of the date of the assessment notice or the date of receipt of the notice by the representative of the estate. Although certain findings and conclusions to the contrary were expressed on the record, after reconsideration in light of the...

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