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GEN. FOODS CREDIT v. DIV. OF TAX

Docket No. 011330-2015.

29 N.J. Tax 590 (2017)

GENERAL FOODS CREDIT INVESTORS #3 CORPORATION, PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

Decided: February 22, 2017.

Attorney(s) appearing for the Case

Charles P. Hurley , a member of the bar of the District of Columbia, admitted pro hac vice, for plaintiff (Norton Rose Fulbright US, LLP, attorneys, Andrea L. D'Ambra, Esq. , local counsel, on the briefs).

Michael J. Duffy for defendant ( Christopher S. Porrino , Attorney General of New Jersey, attorney, Paul V. Buonaguro , Deputy Attorney General, on the briefs).

This is the court's opinion with respect to plaintiff's motion for partial summary judgment. At issue is whether assets subject to a sale-leaseback transaction between plaintiff and New Jersey Transit Corporation ("NJ Transit"), and imputed rental income from those assets, should be included in plaintiff's business allocation...

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