SMALL, J.T.C.
Plaintiff, Sharps, Pixley, Inc. ("SPI"), contests the June 3, 1994 denial by the defendant, Director, Division of Taxation, ("Director") of a claim for refund of taxes paid under the Corporation Business Tax Act, N.J.S.A. 54:10A-1 to -40. The matter is before the court on a stipulated record pursuant to R. 8:8-1(b).
There is no dispute that for the tax years 1980, 1981, 1983 and 1984, SPI overpaid its corporation business tax (...
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