Legal Opinion

S.M.Z. Corp. v. Director, Division of Taxation

New Jersey Tax Court

Decided November 4, 1982PublishedCited by 3 opinions

1Opinion of the Court

HOPKINS, J.T.C.

This is an appeal from the determination by the Director, Division of Taxation, that S.M.Z. Corporation is not authorized to compute its New Jersey Corporation Business Tax, N.J.S.A. 54:10A-1 et seq., by apportioning its income and net worth by taking into consideration real property, located in Connecticut, which it owns and rents.

The tax years and additional assessments are as follows:

*235Fiscal Year1 Ending

Tax

Penalty

Interest To 10/15/78

2/28/73

2/28/74

2/28/75

2/28/76

$ 652.72

2.277.56

2,918.43

2.772.57

$ 32.63

113.87

145.94

138.62

$ 458.53

1,326.67

1,226.90

665.41

S.M.Z. is incorporated under…

2Cases cited30 opinions

  1. Allied Stores of Ohio, Inc. v. BowersSupreme Court of the United States · 1959
  2. Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
  3. Western Live Stock v. Bureau of RevenueSupreme Court of the United States · 1938
  4. Curry v. McCanlessSupreme Court of the United States · 1939
  5. National Bellas Hess, Inc. v. Department of RevenueSupreme Court of the United States · 1967

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3Cited by3 opinions

  1. Hess Realty Corp. v. Director, Division of TaxationNew Jersey Tax Court · 1988
  2. SMZ CORP. v. Taxation Div. DirectorNew Jersey Superior Court Appellate Division · 1984
  3. River Systems, Inc. v. StateNew Jersey Tax Court · 2001

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