Mannino v. Director, Division of Taxation

BIANCO, J.T.C.

Plaintiffs, Philip and Joanne Mannino (collectively hereinafter “the Manninos”; individually “Mr. Mannino” and “Mrs. Mannino,” respectively), filed an appeal against the Director of the Division *435of Taxation (hereinafter “the Director”), challenging the manner in which the Director computed a tax credit for taxes paid to other jurisdictions on the Manninos’ 2003 Gross Income Tax return. The Director argues that when applying the statutory formula for calculating the tax credit, the numerator of the credit fraction (i.e. income subject to tax by all foreign jurisdictions) should…