Legal Opinion
Scully v. Director, Division of Taxation
New Jersey Tax Court
Decided September 21, 2001PublishedCited by 5 opinions
1Opinion of the Court
KUSKIN, J.T.C.
Plaintiffs Michael Scully and James Scully1 are owners of partnership interests in Port-O-Call Associates, L.P., a New Jersey limited partnership (the “Partnership”). They appeal as-' sessments of Gross Income Tax imposed on them by defendant Director for tax year 1992 with respect to income arising from the discharge of indebtedness owed by the partnership. The Director asserts that the Partnership realized the discharge of indebtedness income in connection with its ordinary business operations, and, therefore, the income must be included in plaintiffs’ respee-*555tive distributive…
2Cases cited10 opinions
- Woodward v. CommissionerSupreme Court of the United States · 1970
- Smith v. Director, Division of TaxationSupreme Court of New Jersey · 1987
- Commissioner v. FinkSupreme Court of the United States · 1987
- Sabino v. DirectorNew Jersey Superior Court Appellate Division · 1996
- Dantzler v. Director, Division of TaxationNew Jersey Tax Court · 1999
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3Cited by5 opinions
- Scully v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 2003
- Murphy v. DirectorNew Jersey Tax Court · 2012
- Miller v. Director, Division of TaxationNew Jersey Tax Court · 2001
- Miller v. Director, Division of TaxationNew Jersey Superior Court Appellate Division · 2003
- Smith v. Director, Division of TaxationNew Jersey Tax Court · 2005