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GEN. FOODS CREDIT v. DIV. OF TAX

Docket No. 011330-2015.

29 N.J. Tax 590 (2017)

GENERAL FOODS CREDIT INVESTORS #3 CORPORATION, PLAINTIFF, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT.

Tax Court of New Jersey.

Decided: February 22, 2017.

Attorney(s) appearing for the Case

Charles P. Hurley, a member of the bar of the District of Columbia, admitted pro hac vice, for plaintiff (Norton Rose Fulbright US, LLP, attorneys, Andrea L. D'Ambra, Esq., local counsel, on the briefs).

Michael J. Duffy for defendant (Christopher S. Porrino, Attorney General of New Jersey, attorney, Paul V. Buonaguro, Deputy Attorney General, on the briefs).

This is the court's opinion with respect to plaintiff's motion for partial summary judgment. At issue is whether assets subject to a sale-leaseback transaction between plaintiff and New Jersey Transit Corporation ("NJ Transit"), and imputed rental income from those assets, should be included in plaintiff's business allocation...

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