Legal Opinion
Pennoyer v. Taxation Division Director
New Jersey Tax Court
Decided May 31, 1983PublishedCited by 13 opinions
1Opinion of the Court
LASSER, P.J.T.C.
Taxpayer trustee contests a deficiency tax assessment of $100.68 for the fiscal year ended February 29, 1980, imposed by the Director of the Division of Taxation under the New Jersey Gross Income Tax Act, N.J.S.A. 54A:1-1 et seq. The assessment was imposed on the undistributed income of a testamentary trust created by the will of a New Jersey domiciliary. The ti’ustee, beneficiaries and assets of the trust are all located outside New Jersey.
The Director has moved to dismiss taxpayer’s complaint as untimely filed. Both the taxpayer and the Director have moved for summary…
2Cases cited21 opinions
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
- Shaffer v. CarterSupreme Court of the United States · 1920
- Miller Brothers Co. v. MarylandSupreme Court of the United States · 1954
- Curry v. McCanlessSupreme Court of the United States · 1939
- Winberry v. SalisburySupreme Court of New Jersey · 1950
16 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Estate of Guzzardi v. Director, Division of TaxationNew Jersey Tax Court · 1995
- Chase Manhattan Bank v. GavinSupreme Court of Connecticut · 1999
- Potter v. Taxation Division DirectorNew Jersey Tax Court · 1983
- Swift v. Director of RevenueSupreme Court of Missouri · 1987
- District of Columbia v. Chase Manhattan BankDistrict of Columbia Court of Appeals · 1997
8 more not listed; retrieve them via the Exa API.