Rollins Leasing Corp. v. Director

LASSER, P.J.T.C.

Rollins Leasing Corp. (taxpayer) contests a corporation business tax (CBT) deficiency assessment imposed by the Director of the Division of Taxation (Director) and contends that Director improperly disallowed deductions for interest paid on promissory notes issued by taxpayer. Director determined that interest payments made by taxpayer to Continental Illinois National Bank and Trust Company of Chicago were not paid on account of an obligation owed to the bank, but were paid on an obligation owed to its corporate parent, Rollins Truck Leasing Corporation (RTL). Director…