BIANCO, J.T.C.
This is the court's opinion regarding the appeal of plaintiff, Residuary Trust A u/w/o Fred E. Kassner, Michele Kassner, Trustee, contesting the deficiency assessment of $192,379 including interest and penalties to March 19, 2009, imposed by defendant, Director of the Division of Taxation ("Director") under the New Jersey Gross Income Tax Act, N.J.S.A. 54A:1-1 et seq. ("Act"). The assessment was imposed on the undistributed income of the testamentary...
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