Legal Opinion
Pfizer Inc. v. Director, Division of Taxation
New Jersey Tax Court
Decided May 29, 2008PublishedCited by 4 opinions
1Opinion of the Court
KUSKIN, J.T.C.
In these matters plaintiffs appeal assessments of corporation business tax (“CBT”) imposed by defendant, Director of the New Jersey Division of Taxation (“Director”). The assessments resulted from the Director’s application of a statutory provision commonly referred to as the “Throwout Rule” in apportioning income of each plaintiff to New Jersey for tax purposes. The Throwout Rule is contained in N.J.S.A 54:10A-6(B), a section of the New Jersey Corporation Business Tax Act, N.J.S.A. 54:10A-1 to -41 (“CBT Act”). Plaintiffs’ respective appeals challenge the facial…
2Cases cited33 opinions
- United States v. SalernoSupreme Court of the United States · 1987
- City of Chicago v. MoralesSupreme Court of the United States · 1999
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Quill Corp. v. North Dakota Ex Rel. HeitkampSupreme Court of the United States · 1992
- Wisconsin v. J. C. Penney Co.Supreme Court of the United States · 1941
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3Cited by4 opinions
- Whirlpool Properties, Inc. v. DIR., DIV. OF TAX.Supreme Court of New Jersey · 2011
- In re Contest of November 8, 2011 General Election of Office of New Jersey General AssemblySupreme Court of New Jersey · 2012
- International Business Machines Corp. v. DirectorNew Jersey Tax Court · 2011
- Whirlpool Properties, Inc. v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 2010