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SEA-LAND SERV., INC. v. DIR., DIV. OF TAX.

16 N.J. Tax 132 (1996)

SEA-LAND SERVICE, INC., PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey

September 27, 1996.

Attorney(s) appearing for the Case

Michael A. Guariglia for plaintiff (McCarter & English, attorneys).

Marlene G. Brown for defendant (Deborah T. Poritz, Attorney General of New Jersey).

KAHN, J.T.C.

This litigation involves the corporation business tax (CBT), and this court's review of a determination of the Director of the Division of Taxation denying a request by plaintiff to offset its overpayments thereunder against CBT obligations of two related corporations which ultimately merged into plaintiff. Based upon undisputed facts, the issue was crystallized by cross motions for summary judgment.

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