CONLEY, J.T.C.
The Director of the Division of Taxation issued a letter ruling on April 25, 1979 concluding that payments made by plaintiff for the lease or purchase of the components of its computer system were subject to sales tax pursuant to the Sales and Use Tax Act, N.J.S.A. 54:32B-1 et seq. Plaintiff thereupon, under protest, satisfied its sales tax liability. In the meantime, plaintiff
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