Schiff v. Director, Division of Taxation

CRABTREE, J.T.C.

Plaintiffs1 seek review of defendant’s determination of a deficiency in gross income tax for the taxable year 1988 in the amount of $178,593.75, including a 5% late payment penalty and interest' calculated to May 16, 1992. Defendant determined that, in computing plaintiffs distributive share of gain from the disposition of partnership property, the property’s adjusted basis for federal income tax purposes must be used, even though plaintiff derived no tax benefit for New Jersey gross income tax purposes in prior years from his share of partnership losses, which were primarily…