Legal Opinion
United Parcel Service General Services v. Division of Taxation (072421)
Supreme Court of New Jersey
Decided December 4, 2014No. A-16/17-13PublishedCited by 4 opinions
1Per curiam
This appeal arises from the New Jersey Division of Taxation’s assessment of late payment and tax amnesty penalties under the New Jersey Corporation Business Tax Act, N.J.S.A. 54:49-6(a), N.J.S.A. 54:53-17, -18, against plaintiffs, five subsidiaries of United Parcel Service of America (UPS).
Following a trial, the Tax Court determined that the Division reasonably had concluded that two categories of routine, inter-company transfers of funds, conducted by plaintiffs as part of the cash management system used by UPS and its affiliates, constituted loans as to which interest should be imputed for…
2Cases cited7 opinions
- Metromedia, Inc. v. Director, Division of TaxationSupreme Court of New Jersey · 1984
- Koch v. Director, Division of TaxationSupreme Court of New Jersey · 1999
- Oberhand v. Director, Division of TaxationSupreme Court of New Jersey · 2008
- Yilmaz, Inc. v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 2007
- United Parcel Service General Services Co. v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 2013
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3Cited by4 opinions
- Timber Glen Phase III, LLC and Jsm at Timber Glen, LLC Vs.New Jersey Superior Court Appellate Division · 2015
- ALCATEL-LUCENT USA INC. VS. TOWNSHIP OF BERKELEY HEIGHTS (TAX COURT OF NEW JERSEY)New Jersey Superior Court Appellate Division · 2019
- De Rosa v. Director, Division of TaxationNew Jersey Tax Court · 2015
- XPEDITE SYSTEMS, INC. VS. DIRECTOR, DIVISION OF TAXATION (TAX COURT OF NEW JERSEY)New Jersey Superior Court Appellate Division · 2020