1. Home
  2. Browse Decisions
  3. N.J.
  4. 26 N.J.
  5. 26 N.J. Tax 102 (2011)
 

INTERN. BUSINESS MACHINES CORP. v. DIR. DIV. OF TAX.

Docket No. 011630-2008, DOCKET NO. 011795-2009

26 N.J. Tax 102 (2011)

INTERNATIONAL BUSINESS MACHINES CORPORATION, Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant. CRESTRON ELECTRONICS, INC., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant.

Tax Court of New Jersey.

January 26, 2011.

Attorney(s) appearing for the Case

Peter L. Faber of the New York bar, admitted pro hac vice, and Leah Samit Robinson , for plaintiff International Business Machines Corporation (McDermott Will & Emery, LLP, attorneys).

Paul H. Frankel and Mitchell A. Newmark , for plaintiff Crestron Electronics, Inc. (Morrison & Foerster, LLP, attorneys).

Marlene G. Brown and Michael J. Duffy , for defendant ( Paula T. Dow , Attorney General of New Jersey, attorney).

DeALMEIDA, P.J.T.C.

The question before the court is whether, during the period at issue, a corporation's entire net income for New Jersey corporation business tax ("CBT") purposes included the taxpayer's extra-territorial income as that term was defined in I.R.C. § 114(e). For the reasons explained more fully below, the court concludes that New Jersey law couples a corporation's entire net income for CBT purposes to its federal taxable income as defined...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases