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ROCKLAND ELECTRIC COMPANY v. DIRECTOR, DIVISION OF TAXATION

DOCKET NO. A-4522-17T2.

31 N.J. Tax 207 (2019)

ROCKLAND ELECTRIC COMPANY, PLAINTIFF-APPELLANT, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-RESPONDENT.

Superior Court of New Jersey, Appellate Division.

Decided June 24, 2019.

Attorney(s) appearing for the Case

Alysse McLoughlin argued the cause for appellant (McDermott Will & Emery LLP, attorneys; Alysse McLoughlin, on the briefs).

Michael J. Duffy , Deputy Attorney General, argued the cause for respondent ( Gurbir S. Grewal , Attorney General, attorney; Melissa H. Raksa , Assistant Attorney General, of counsel; Michael J. Duffy, on the brief).

Michael J. Duffy, Deputy Attorney General, argued the cause for respondent (Gurbir S. Grewal, Attorney General, attorney; Melissa H. Raksa, Assistant Attorney General, of counsel; Michael J. Duffy, on the brief).

Plaintiff Rockland Electric Company appeals from the April 30, 2018 Tax Court order, granting defendant Director, Division of Taxation, summary judgment, and denying plaintiff's motion for summary judgment. In a written opinion, Judge Vito L. Bianco accepted defendant's position that the Transitional Energy Facility

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