LASSER, P.J.T.C.
This is a motion by the Director of the Division of Taxation, defendant, to dismiss the complaint of the taxpayer for failure to state a claim upon which relief can be granted. The original motion to dismiss was converted by the court to a motion for summary judgment by permitting taxpayer to complete requested discovery and submit an offer of proof containing all of the facts that he intended to present if the case were tried.
Taxpayer seeks...
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