Eiszner v. Director, Division of Taxation

The opinion of the court was delivered by

STERN, P.J.A.D.

Plaintiff, Joyce H. Eiszner, appeals from a judgment of the Tax Court entered on January 21, 2000, affirming the Director of the Division of Taxation’s final determination of an assessment on plaintiffs 1992 non-resident gross income tax return. The Tax *500Court concluded that the assessment was not barred by the three-year statute of limitations provided in N.J.S.A-. 54A:9-4(a), and adjudicated as taxable income the disputed income from a New Jersey resident trust. The Director, upheld by the Tax Court, concluded that a sum of $1,069,213,…