United Parcel Service General Services Co. v. Director, Division of Taxation

The opinion of the court was delivered by

LIHOTZ, J.A.D.

The defendant Director of the New Jersey Division of Taxation (the Director) appeals from the final order of the Tax Court of New Jersey in these matters, consolidated for trial. Plaintiffs are five entities of the United Parcel Service group of companies (UPS Group), each of which is a subsidiary of United Parcel Service of America, Inc. (America), the parent corporation.1 United Parcel Service General Services Co. (GS), UPS Telecommunications, Inc. (Telecom), UPS Worldwide Forwarding, Inc. (WWF), UPS Worldwide Forwarding, Inc. as…