HOPKINS, J.T.C.
This is an appeal from the determination by the Director, Division of Taxation, that S.M.Z. Corporation is not authorized to compute its New Jersey Corporation Business Tax, N.J.S.A. 54:10A-1 et seq., by apportioning its income and net worth by taking into consideration real property, located in Connecticut, which it owns and rents.
The tax years and additional assessments are as follows:
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