Village Super Market of PA, Inc. v. Director, Division of Taxation

BRENNAN, J.T.C.

This constitutes the court’s opinion after trial in the above-referenced matter. The dispute at issue is whether the plaintiff, Village Super Market of PA, Inc., (“PA”) is subject to New Jersey Corporation Business Tax (“CBT”) pursuant to N.J.S.A. 54:10A-1 for the period of October 28, 1999 to the present. The defendant, Director, Division of Taxation (“Director”), asserts that PA has nexus with New Jersey and that its business is integrally related to a New Jersey business by virtue of its limited partnership interest in a New Jersey entity.

For the reasons set forth below, the…