Lorillard Licensing Co. v. Director, Division of Taxation

DeALMEIDA, P.J.T.C.

This opinion is issued pursuant to R. 2:5-l(b) to amplify the court’s August 9, 2013 bench opinion granting partial summary judgment in favor of Lorillard Licensing Co., LLC in the above-referenced matter. The effect of the court’s decision was memorialized in a Final Order and Final Judgment dated November 15, 2013. The Director, Division of Taxation filed a Notice of Appeal with the Superior Court, Appellate Division, on December 30, 2013.

I. Findings of Fact and Procedural History

This letter opinion sets forth the court’s findings of fact and conclusions of law based on…