Legal Opinion

Cities Service Co. v. Director, Division of Taxation

New Jersey Tax Court

Decided February 24, 1983PublishedCited by 2 opinions

1Opinion of the Court

CONLEY, J.T.C.

This case involves the issue of what constitutes “the books of the corporation” for purposes of computing a taxpayer’s net worth under the Corporation Business Tax Act (1945), N.J.S.A. 54:10A-1 et seq. Plaintiff challenges an assessment of additional taxes under the act by the Director, who made certain recomputations of plaintiff’s 1975 and 1976 returns following his audit for those years. The parties have stipulated that the relevant adjustments made by the Director were on plaintiff’s schedules 0 (deductions for subsidiaries) and Q (subsidiary investment exclusion) and that…

2Cases cited14 opinions

  1. R. H. MacY & Co. v. Director, Division of TaxationSupreme Court of New Jersey · 1963
  2. Roadway Express, Inc. v. Director, Division of TaxationSupreme Court of New Jersey · 1967
  3. R. H. Macy & Co. v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 1962
  4. F. W. Woolworth Co. v. Director of Division of Taxation of the Department of the TreasurySupreme Court of New Jersey · 1965
  5. Sims v. CohenSupreme Court of the United States · 1968

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3Cited by2 opinions

  1. Amerada Hess Corp. v. Director, Division of TaxationSupreme Court of New Jersey · 1987
  2. Bristol-Myers Co. v. Taxation Division DirectorNew Jersey Tax Court · 1986

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