Eiszner v. Director, Division of Taxation

AXELRAD, J.T.C.

In this state tax matter concerning the New Jersey Gross Income Tax Act, N.J.S.A. 54A:1-1 to :10-12, the taxpayer appeals the Director's June 5, 1998 Final Determination assessing additional tax and interest. The taxpayer contests the Director’s assessment on two grounds: First, the taxpayer contends that the *582Final Determination was time-barred by N.J.S.A. 54A:9-4(a), which limits the time in which the Director may assess any tax under the Gross Income Tax Act to three years after the taxpayer’s return was filed. Second, the taxpayer argues that, even if the Director’s…