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N.J. NATURAL GAS CO. v. DIR., DIV. OF TAXATION

24 N.J. Tax 59 (2008)

NEW JERSEY NATURAL GAS CO., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant.

Tax Court of New Jersey.

April 17, 2008.

Attorney(s) appearing for the Case

Stephen Orlofsky and Kit Applegate (Blank Rome, LLP, attorneys), and Michael J. Semes and Robert P. Harrill, Jr. of the Pennsylvania bar admitted pro hac vice, for plaintiff.

Heather L. Anderson for defendant (Anne Milgram, Attorney General of New Jersey, attorney).

SMALL, P.J.T.C.

Corporations doing business in New Jersey are subject to New Jersey's Corporation Business Tax. N.J.S.A. 54:10A-1 to -32. If all of a corporation's activities and property are in New Jersey, 100% of its income is subject to tax in New Jersey. If less than 100% of the corporation's activities and property are in New Jersey, its income is apportioned to New Jersey under a statutory formula. If the corporation maintains a regular place of business...

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