Dahyabhai S. v. Director

PIZZUTO, J.T.C.

Plaintiff taxpayers contest a final determination of the Director of the Division of Taxation (hereinafter “the Director”), imposing interest and penalty charges on late payment of their 1987 gross income tax. They claim that they are entitled to abatement of all, or at least a portion, of the penalties imposed and of the amount of *512interest in excess of 3% over the prime rate. They base this contention on the full payment of all tax due within four months of the April 15, 1988 reporting date and an ineffective attempt to obtain an extension of time to the date of actual…