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FLAGSTAR BANK v. DIR. OF TAX.

Docket No. 019335-2010.

29 N.J.Tax 130 (2016)

FLAGSTAR BANK, FSB, PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

Decided: March 22, 2016.

Attorney(s) appearing for the Case

Michael A. Guariglia and David J. Shipley , Newark, for plaintiff (McCarter & English, LLP, attorneys).

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

This is the court's opinion after trial in the above-referenced matter. At issue is the imposition of the New Jersey Corporate Business Tax ("NJ CBT" or "CBT") on a foreign multi-state banking institution that originates and acquires mortgage loans made to New Jersey borrowers. Specifically, the taxpayer contests (1) the inclusion...

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