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INTERN. PAPER CO. v. TAXATION DIV. DIR.

11 N.J. Tax 147 (1990)

INTERNATIONAL PAPER CO., PLAINTIFF, v. TAXATION DIVISION DIRECTOR, DEFENDANT.

Tax Court of New Jersey.

Decided April 26, 1990.

Attorney(s) appearing for the Case

Charles M. Costenbader and Charles H. Friedrich for plaintiff (Stryker, Tams & Dill, attorneys).

Herbert K. Glickman for defendant (Robert J. Del Tufo, Attorney General of New Jersey, attorney).

Before Judges ANDREW, CRABTREE, HOPKINS, LARIO, LASSER & RIMM pursuant to 8:8-6.

The opinion of the court was delivered by LASSER, P.J.T.C.

Plaintiff, International Paper Company ("IP"), contests the Director's denial of refund claims for corporation business tax paid for tax years 1981 and 1982. IP contends that two items of income are not properly includable in its "adjusted entire net income" because this income was not earned as part of IP's unitary business. The items of income at issue are:

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