DeALMEIDA, P.J.T.C.
The issue before the court is whether R. 4:50-1 vests this court with jurisdiction to vacate a Certificate of Debt issued against a taxpayer by the Director, Division of Taxation pursuant to N.J.S.A. 54:49-12. For the reasons stated more fully below, the court concludes that a taxpayer may not use R. 4:50-1 as a vehicle for challenging the validity of a Certificate of Debt issued by the Director. Plaintiff's complaint, therefore...
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