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UNITED PARCEL SER. v. DIR. OF TAX.

No. 007845-2004, 007879-2004, 007889-2004, 007890-2004, 007891-2004

25 N.J. Tax 1 (2009)

UNITED PARCEL SERVICE GENERAL SERVICES CO., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant. UPS TELECOMMUNICATIONS, INC., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant. UNITED PARCEL SERVICE CO., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant. UPS WORLDWIDE FORWARDING, INC., AS SUCCESSOR IN INTEREST TO, UPS AIR FORWARDING, INC., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant. UPS WORLDWIDE FORWARDING, INC., Plaintiff, v. DIRECTOR, DIVISION OF TAXATION, Defendant.

Tax Court of New Jersey.

June 5, 2009.

Attorney(s) appearing for the Case

Michael James Guerriero (Day Pitney LLP, attorneys) and Richard D. Birns and J. Edward Goff of the Pennsylvania bar, admitted pro hoc vice (Birns & Goff, attorneys) for plaintiffs.

Marlene G. Brown, Deputy Attorney General, for defendant (Anne Milgram, Attorney General of New Jersey, attorney).

KUSKIN, J.T.C.

I.

                            TABLE OF CONTENTS

  I. Introduction ........................................   7

 II. Years and Assessments In Issue ......................   7

III. Issues ..............................................   8

 IV. General Factual Background ..........................  11

  V. Applicable Legal Principles .........................  12

 VI. Discussion and Analysis of Issues .......

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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