Clorox Products Manufacturing, Co. v. Director, Division of Taxation

The opinion of the court was delivered by

LINTNER, J.A.D.

The Director of the Division of Taxation (Director or Division) appeals the Tax Court’s reversal of a Corporation Business Tax (CBT) Act, N.J.S.A. 54:10A-1 to -41, assessment against Clorox Products Manufacturing Company (Taxpayer) in the amount of $84,924.43 for the years 1998, 1999, and 2000, including a five *225percent post-amnesty penalty under N.J.S.A. 54:53-18. Taxpayer sought CBT depreciation deductions taken for assets received in a 1996 stock-for-asset swap with its parent, The Clorox Company (Parent), by continuing to report the…