ESTATE OF GUZZARDI v. DIR., DIV. OF TAXATION


15 N.J. Tax 395 (1995)

ESTATE OF TINA GUZZARDI, PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

December 6, 1995.


Attorney(s) appearing for the Case

Gary W. Calvin for plaintiff (MaCary & Calvin, attorneys).

Patrick DeAlmeida for defendant (Deborah T. Poritz, Attorney General of New Jersey, attorney).


HAMILL, J.T.C.

There are two principal issues in this gross income tax case. The first is whether, in light of Baldwin v. Director, Div. of Taxation, 10 N.J.Tax 273 (Tax 1988), aff'd per curiam o.b., 237 N.J.Super. 327, 567 A.2d 1021 (App.Div. 1990), plaintiff is entitled to offset a 1988 installment sale gain with a capital loss carryover...

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