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REGENT CORP. v. DIR. OF TAXATION

DOCKET NO. 013971-2010

27 N.J. Tax 577 (2014)

REGENT CORPORATION OF UNION, INC., PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

Decided: January 17, 2014.

Attorney(s) appearing for the Case

Bruce E. Mantell for plaintiff (Mantell, Prince & Reynolds, PC, attorneys).

Michael J. Duffy for defendant ( John J. Hoffman , Acting Attorney General of New Jersey, attorney).

NUGENT, J.T.C.

This matter brought before the court on cross-motions for summary judgment presents a question of statutory interpretation. Specifically, whether regulation N.J.A.C. 18:7-1.15 enacted by the Division of Taxation ("Division") to qualify an "investment company" constitutes a reasonable interpretation of N.J.S.A. 54:10A-4(f), a provision of the New Jersey Corporation Business Tax Act (CBT), N.J.S.A. 54:10A-1 to 41. The Division denied...

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