Legal Opinion
CIT Financial Services Consumer Discount Co. v. Director, Division of Taxation
New Jersey Tax Court
Decided September 17, 1982PublishedCited by 5 opinions
1Opinion of the Court
CRABTREE, J.T.C.
Plaintiff seeks review of defendant’s determination that plaintiff is subject to the New Jersey Corporation Income Tax *571Act, N.J.S.A. 54:10E-1 et seq., for the calendar years 1976 and 1977. The determination is based upon income attributable to loans made by plaintiff to New Jersey residents. Plaintiff claims that the determination and any tax assessed pursuant thereto violate the Due Process and Commerce Clauses of the United States Constitution as plaintiff is engaged solely in interstate commerce with no contacts with the State of New Jersey.
The facts are fully stipulated…
2Cases cited28 opinions
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
- Northwestern States Portland Cement Co. v. MinnesotaSupreme Court of the United States · 1959
- Western Live Stock v. Bureau of RevenueSupreme Court of the United States · 1938
- Commonwealth Edison Co. v. MontanaSupreme Court of the United States · 1981
23 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Avco Financial Services Consumer Discount Co. v. Director, Division of TaxationSupreme Court of New Jersey · 1985
- Chemical Realty Corp. v. Taxation Division DirectorNew Jersey Tax Court · 1983
- Estate of Ehringer v. Director, Division of TaxationNew Jersey Tax Court · 2009
- Continental Trailways, Inc. v. Director, Division of Motor VehiclesNew Jersey Tax Court · 1983
- Avco Financial Services Consumer Discount Co. v. Director, Division of TaxationSupreme Court of New Jersey · 1985