The opinion of the court was delivered by BURLING, J.
This appeal was addressed to the Superior Court, Appellate Division, as an action in lieu of the former prerogative writ of certiorari under Rule 3:81, by Joseph J. Hooton and Robert W. Hill, executors of the last will and testament of Hu Woodward, deceased (hereinafter termed the appellants) against Aaron K. Neeld, Deputy Director, Division of Taxation, Department of the Treasury, State of New Jersey...
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