King v. Director, Division of Taxation

Plaintiff, Diana King, appeals from a summary judgment entered by the Tax Court, dismissing her complaint and affirming the issuance by the Director of the New Jersey Division of Taxation (Director or Division) of a notice of deficiency to plaintiff. Specifically, the court found that plaintiff impermissibly offset her gains from the sale of property with a nondeductible nonbusiness bad debt and, therefore, underpaid her 1996 state income taxes. We affirm.

The facts are undisputed. On April 4, 1991, plaintiff, in her individual capacity, entered into a $650,000 loan agreement with Imero…