Pantasote, Inc. v. Director, Division of Taxation

HOPKINS, J.T.C.

Plaintiff (taxpayer) seeks a refund of 1980 and 1981 business personal property (BPP) taxes paid. In the event taxpayer’s refund is barred by the statute of limitations, it requests that the BPP tax overpayment be setoff against taxpayer’s sales and use tax liability.

Taxpayer, a corporation which maintains its principal offices in Greenwich, Connecticut, manufactures and sells wall coverings and plastic products both within and without the State of New Jersey. In the late 1970s, taxpayer acquired all of the outstanding shares of stock of another corporation, Panta Astor, Inc.…