Corallo's, Inc. v. Director, Division of Taxation

MENYUK, J.T.C.

This matter comes before the court following the denial without prejudice of plaintiff’s motion for partial summary judgment. The motion sought to invalidate certain assessments of taxes for periods prior to June 1, 1998 on the ground that the assessments were made beyond the periods permitted by the relevant statutes of limitations for the assessment of tax deficiencies by the Division of Taxation (“Division”). It was plaintiff’s contention that consents signed by plaintiff’s former accountant waiving the statutes of limitation were invalid because the plaintiff had not…