Willett v. Director, Div. of Taxation

ANDREW, J.T.C.

This is a state tax case involving the New Jersey Gross Income Tax Act, N.J.S.A. 54A:1-1 et seq. The issue in this matter focuses on the proper computation of the “resident credit” to be allowed plaintiffs, Joseph T. and Janice M. Willett, pursuant to N.J.S.A. 54A:4-1 for taxes plaintiffs paid to other taxing jurisdictions.

Defendant, Director of the Division of Taxation, calculated plaintiffs’ credit for taxes paid to other taxing jurisdictions in three distinct steps while plaintiffs maintain that there is no authority for the Director to calculate the resident credit in the…