Rollins Leasing Corp. v. Director

The opinion of the court was delivered by

PETRELLA, P.J.A.D.

This appeal concerns whether Rollins Leasing Corporation (Rollins), the taxpayer, properly deducted interest expenses on certain notes payable to a trustee for debenture holders on its Corporation Business Tax (CBT) returns for the years between October 1, 1984 and September 30,1989. Rollins appeals from the December 13, 1993 order and final judgment entered in favor of the Director, *542Division of Taxation (Director), by the Tax Court, which upheld the Director’s disallowance of certain interest deductions.

The matter was tried in the…