Rose, J.
Mary Tyborowski (hereinafter Tyborowski) and Hattie Tyborowski (hereinafter decedent) were sisters who resided in New Jersey and held their property jointly until decedent died in March 1988, leaving Tyborowski as her sole distributee. From that time until her death in January 1995, Tyborowski never probated her sister's estate and never filed an inheritance tax return with the New Jersey Department of Treasury (hereinafter the Department). In September 1996...
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