LARIO, J.T.C.
Plaintiffs filed a complaint to reverse a deficiency assessment against them for additional New Jersey income taxes claimed due. Both parties have now filed cross-motions for summary judgment.
Involved is the interpretation of the New Jersey Gross Income Tax Act, N.J.S.A. 54A:1-1 et seq. (act). The portion of the act which is at the heart of the controversy, § 9-27(a), reads as follows:
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