Brunswick Corp. v. Director

The opinion of the court was delivered by

LONG, J.A.D.

Plaintiff, Brunswick Corporation, appeals from a Tax Court decision which affirmed a final determination of the Director of the Division of Taxation imposing Corporation Business Tax (CBT) deficiency assessments on plaintiff for 1986 and 1987. The deficiencies arose from plaintiffs failure, contrary to N.J.AC. 18:7-8.5(b) and (c), to take into account property which it leased in computing the property allocation factor under N.J.S.A 54:10A-6(A). Plaintiff argues that N.J.AC. 18:7-8.5(b) and (c) conflict with the plain meaning of N.J.S.A.…