Residuary Trust v. Director, Division of Taxation

The Director of the State Division of Taxation (Division or State) appeals from a January 3, 2013 decision of the Tax Court holding that the taxpayer, the Residuary Trust A U/W/O Fred E. *543Kassner (the Trust or the taxpayer), did not owe $192,379 in taxes plus interest and penalties, on the Trust’s undistributed out-of-State income for the year 2006. Residuary Trust A v. Dir., Div. of Taxation, 27 N.J.Tax 68 (Tax 2013). The Tax Court granted summary judgment in favor of the Trust. We affirm.

The facts and procedural history are recited at length in the Tax Court’s opinion and will not be…