R. H. MacY & Co. v. Director, Division of Taxation

Pee Cubiam:.

The judgment is affirmed for the reasons expressed by Judge Conford in his opinion for the Appellate Division. See 77 N. J. Super. 155 (1962). That opinion declined to pass on the issue of discrimination because it had not been raised before tbe Division of Tax Appeals; we note that the issue was similarly not included in the points set forth in the brief filed by the appellant in this court. Although we have subscribed to the Appellate Division’s treatment of the final issue captioned “Administrative Rule-Making by Adjudication” (77 N. J. Super., at p. 179), we take this occasion…