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DELMARVA POWER & LIGHT CO. v. DIRECTOR, DIV. OF TAXATION

23 N.J. Tax 188 (2006)

DELMARVA POWER & LIGHT CO., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant.

Tax Court of New Jersey

July 14, 2006.

Attorney(s) appearing for the Case

James B. Evans, Jr. for plaintiff (Kulzer & Dipadova, P.A., attorneys).

Marlene G. Brown for defendant (Zulima V. Farber, Attorney General of New Jersey, attorney).

SMALL, P.J.T.C.

Plaintiff, Delmarva Power and Light Company ("Delmarva"), argues that, because of the way in which provisions of the New Jersey Corporation Business Tax Act (the "CBT Act"), N.J.S.A. 54:10A-1 to -40, and the New Jersey Franchise and Gross Receipts Tax Act (the "F & GRT Act"), N.J.S.A. 54:30A-16 to -67 (repealed by L. 1997, c. 162, § 77, effective Jan. 1, 1998), were worded for the years 1994 to 1997, it (Delmarva...

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