Legal Opinion
CSX Transportation, Inc. v. Director, Division of Taxation
New Jersey Tax Court
Decided June 9, 2005PublishedCited by 1 opinion
1Opinion of the Court
KAHN, J.T.C.
This is the court’s determination with respect to cross-motions for summary judgment involving railroad franchise tax assessments made by the Director, Division of Taxation, pursuant to *403N.J.S.A. 54:29A-14.1 In these cases, CSX and Norfolk (collectively, taxpayers)2 , Virginia corporations, contest the Division’s assessments of New Jersey Railroad Franchise Tax, N.J.S.A. 54:29A-13 to -15 (RFT). The essence of taxpayers’ claims is twofold: (1) the statutorily-prescribed RFT allocation formula should be interpreted to require the allocation to be calculated on a proportion of shared…
2Cases cited19 opinions
- Brill v. Guardian Life Insurance Co. of AmericaSupreme Court of New Jersey · 1995
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Quill Corp. v. North Dakota Ex Rel. HeitkampSupreme Court of the United States · 1992
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Mobil Oil Corp. v. Commissioner of Taxes of Vt.Supreme Court of the United States · 1980
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3Cited by1 opinion
- CSX Transportation, Inc. v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 2007