McCauley v. State

PIZZUTO, J.T.C.

This case concerns the taxability under the New Jersey Gross Income Tax Act (N.J.S.A. 54A:1-1 through:9-27) of the proceeds of a partial assignment of a New Jersey State Lottery prize, payable in installments over a period of years. Plaintiffs, Thomas McCauley (hereinafter “McCauley”) and his wife Loretta, filed a joint Gross Income Tax Return for 1994 and contest a deficiency assessment made by the defendant Director,of the Division of Taxation (hereinafter “Director”) with respect to then* Gross Income Tax liability for that year. In particular, the Director included in…