Praxair Tech. v. Dir., Div. of Taxation

This appeal presents a narrow question: whether, in the circumstances presented, an out-of-state taxpayer is liable for New Jersey’s corporate business tax for the years 1994-1996. The Director of the Division of Taxation asserted, and the Tax Court agreed, that the taxpayer’s business activities were subject to New Jersey’s Corporation Business Tax Act of 1945, N.J.S.A 54:10A-1 to -41, and that the 1996 addition of an example to the applicable regulation effected no change in tax policy or obligations. Conceding its business activities clearly were subject to New Jersey’s corporate business…