PIZZUTO, J.T.C.
Plaintiffs contest the determination of the Director of the Division of Taxation concerning their claim that a particular conveyance of real property is exempt from the realty transfer fee imposed by N.J.S.A. 46:15-5 to -11. The conveyance was one in a series of transactions structured to accomplish a tax free exchange of like-kind property under I.R.C. § 1031. The material facts are not in dispute and both plaintiffs and defendants...
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