Suburban Coastal Corp. v. Glaser

KAHN, J.T.C.

Plaintiff contests the validity of assessments imposed by defendant pursuant to the Corporation Business Tax Act, N.J. S.A. 54:10A-1 et seq. Plaintiff contends that it is a financial business corporation and therefore entitled to deduct 100% of interest expenses relating to its indebtedness to an affiliated corporation in accordance with N.J.S.A. 54:10A-4(d) and -4(k)(2)(E)(iii). The Division of Taxation disagreed and imposed taxes, penalties and interest for plaintiff’s fiscal years ending June 30, 1978, 1979 and 1980 in the following amounts:

1978 1979 1980

Tax $ 26,527.00…