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

17 N.J. Tax 591 (1998)

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

Superior Court of New Jersey, Appellate Division

Decided February 6, 1998

Attorney(s) appearing for the Case

Michael A. Guariglia, argued the cause for appellant (McCarter & English, attorneys; Mr. Guariglia, of counsel and on the brief; John K. Bradley also on the brief).

Marlene G. Brown, Deputy Attorney General, argued the cause for respondent (Peter Verniero, Attorney General, attorney; Joseph L. Yannotti, Assistant Attorney General, of counsel; Ms. Brown, on the brief).

Before Judges SKILLMAN, EICHEN and STEINBERG.

PER CURIAM.

Plaintiff Sea-Land Service, Inc. appeals from a final judgment entered in the Tax Court granting summary judgment to defendant Director, Division of Taxation. Plaintiff had argued that it was entitled to offset its overpayment of corporate business taxes (CBT) against tax liabilities it incurred as the result of its merger with its parent company and a subsidiary company. In a comprehensive published opinion, the Tax Court judge rejected plaintiff's argument...

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