BIANCO, J.T.C.
Defendant, Director, Division of Taxation ("the Director"), and the plaintiff, Estate of Stanley Kosakowski ("the Estate"), filed cross-motions for summary judgment with regard to the Director's denial of a $109,545 refund claim made by the Estate. This opinion shall serve as the court's determination of said cross-motions.
The Director asserts that the Estate's refund claim was properly denied since this matter is distinguishable from Oberhand...
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