Legal Opinion
Tuition Plan of New Hampshire v. Director, Division of Taxation
New Jersey Tax Court
Decided July 28, 1982PublishedCited by 7 opinions
1Opinion of the Court
CRABTREE, J. T. C.
Plaintiff seeks review of defendant’s determination that plaintiff is subject to the New Jersey Corporation Income Tax Act, N.J.S.A. 54:10E-1 et seq. for the calendar years 1974 through 1977. The determination is based upon income attributable to loans made by plaintiff to New Jersey residents. Plaintiff claims that the determination and any tax assessed pursuant thereto violate the Due Process and Commerce Clauses of the United States Constitution, as plaintiff is engaged solely in interstate commerce with no contacts with the State of New Jersey.
The facts are fully…
2Cases cited27 opinions
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
- Northwestern States Portland Cement Co. v. MinnesotaSupreme Court of the United States · 1959
- Western Live Stock v. Bureau of RevenueSupreme Court of the United States · 1938
- Commonwealth Edison Co. v. MontanaSupreme Court of the United States · 1981
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3Cited by7 opinions
- Avco Financial Services Consumer Discount Co. v. Director, Division of TaxationSupreme Court of New Jersey · 1985
- Chemical Realty Corp. v. Taxation Division DirectorNew Jersey Tax Court · 1983
- Estate of Ehringer v. Director, Division of TaxationNew Jersey Tax Court · 2009
- Mayer & Schweitzer, Inc. v. Director, Division of TaxationNew Jersey Tax Court · 2002
- Thomson-Leeds Co. v. Taxation Division DirectorNew Jersey Tax Court · 1985
2 more not listed; retrieve them via the Exa API.