Legal Opinion

Beljakovic v. Director

New Jersey Tax Court

Decided August 1, 2012PublishedCited by 2 opinions

1Opinion of the Court

NARAYANAN, J.T.C.

This is the court’s opinion in connection with the parties’ respective motions for summary judgment in the above captioned Gross Income Tax (“GIT”) matter. The issue presented is whether plaintiffs are eligible for a GIT credit for income taxes paid to New York on passed-through S corporation income. Defendant (“Director”) denied a credit because the S corporation allocated 100% of its income to New Jersey, and pursuant to the GIT statute, N.J.S.A. 54A:4-1(e), no credit is allowed for S corporation income allocated to this State. Plaintiffs argue that the S corporation was…

2Cases cited36 opinions

  1. Brill v. Guardian Life Insurance Co. of AmericaSupreme Court of New Jersey · 1995
  2. Koch v. Director, Division of TaxationSupreme Court of New Jersey · 1999
  3. O'Keefe v. Passaic Valley Water CommissionSupreme Court of New Jersey · 1993
  4. Richard's Auto City, Inc. v. Director, Division of TaxationSupreme Court of New Jersey · 1995
  5. F. W. Woolworth Co. v. Director of Division of Taxation of the Department of the TreasurySupreme Court of New Jersey · 1965

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3Cited by2 opinions

  1. Criticare, Inc. v. Director, Division of TaxationNew Jersey Tax Court · 2014
  2. Fields v. Trustees of Princeton UniversityNew Jersey Tax Court · 2015

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