Metro Touch, Inc. v. Director, Division of Taxation

KUSKIN, J.T.C.

In this appeal plaintiff asserts that defendant, the Director of the New Jersey Division of Taxation, improperly imputed interest income to plaintiff, Metro Touch, Inc., for tax years 1996,1997 and 1998 under the New Jersey Corporation Business Tax Act, N.J.S.A. 54:10A-1 to -41. For the reasons set forth below, I conclude that the imputation of interest was proper.

The parties submitted the matter for decision based upon the following stipulated facts. Plaintiff is a New Jersey corporation wholly owned by Ida Shapiro. The corporation elected to be treated as a Subchapter S…