BANK OF AM. v. DIV. OF TAX.

Docket Nos. 012945-2011, 012947-2011, 012942-2011, 000386-2012, 000387-2012.

29 N.J. Tax 427 (2016)

BANK OF AMERICA CONSUMER CARD HOLDINGS, PLAINTIFF(S), v. STATE OF NEW JERSEY DIVISION OF TAXATION, DEFENDANTS. FLEET CREDIT CARD HOLDINGS INC., PLAINTIFF(S), v. STATE OF NEW JERSEY DIVISION OF TAXATION, DEFENDANTS. FIA CARD SERVICES, N.A., PLAINTIFF(S), v. STATE OF NEW JERSEY DIVISION OF TAXATION, DEFENDANTS. FIA CARD SERVICES, N.A., PLAINTIFF(S), v. STATE OF NEW JERSEY DIVISION OF TAXATION, DEFENDANTS. FIA CARD SERVICES, N.A., PLAINTIFF(S), v. STATE OF NEW JERSEY DIVISION OF TAXATION, DEFENDANTS.

Tax Court of New Jersey.

Decided: October 6, 2016.


Attorney(s) appearing for the Case

Richard A. Leavy for plaintiffs (Sidley Austin, LLP, attorneys).

Michael J. Duffy for defendant ( Christopher S. Porrino , Attorney General of New Jersey, attorney).


I. INTRODUCTION

Bank of America Consumer Card Holdings and related entities (collectively the "taxpayers") are in the credit card account business. The credit card accounts allow customers otherwise known as cardholders to make purchases at or from merchants which accept the cards for payment. The...

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