ANDREW, J.T.C.
In this state tax case plaintiff, The Reuben H. Donnelley Corporation, seeks review of a decision of the Director, Division of Taxation revising the property fraction of plaintiff's business allocation factor for purposes of the Corporation Business Tax Act (CBT), N.J.S.A. 54:10A-1 et seq., for the tax years of 1983 and 1984.
Specifically, plaintiff maintains that the Director's determination to exclude plaintiff's "safe harbor...
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