Chevron U.S.A., Inc. v. City of Perth Amboy

HOPKINS, J.T.C.,

concurring.

I fully agree with the conclusion reached in the majority opinion. Further, I also believe that the same result would be reached, even if c. 117 were not enacted.

*245My conclusion is based upon a review of the definition of personal property, for tax purposes, as set out in Bayonne City v. Port Jersey Corp., 79 N.J. 367, 399 A.2d 649 (1979) and Bostian v. Franklin State Bank, 1 N.J.Tax 270 (Tax Ct.1980), aff’d 179 N.J.Super. 174, 2 N.J.Tax 391, 430 A.2d 1140 (App. Div.1980). Bayonne’s legal principles, as thoughtfully analyzed in the Bostian Tax Court opinion and…