Legal Opinion

First National City Bank v. Taxation Division Director

New Jersey Tax Court

Decided March 23, 1983PublishedCited by 2 opinions

1Opinion of the Court

HOPKINS, J.T.C.

Plaintiff has appealed from the imposition of use taxes, pursuant to the New Jersey Sales and Use Tax Act, on two corporate aircraft owned by it and based in New Jersey. It contends that the aircraft are exempt from the use tax by virtue of N.J.S.A. 54:32B-11(2) and, in any event, the tax violates the Commerce Clause and Equal Protection Clause of the United States Constitution.

Plaintiff is a national banking association created pursuant to 12 U.S.C.A. § 21 et seq., with its principal place of business located at 399 Park Avenue, New York, New York. It is engaged in the…

2Cases cited23 opinions

  1. Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
  2. Henneford v. Silas Mason Co.Supreme Court of the United States · 1937
  3. Spector Motor Service, Inc. v. O'ConnorSupreme Court of the United States · 1951
  4. Southern Pacific Co. v. GallagherSupreme Court of the United States · 1939
  5. Eastern Air Transport, Inc. v. South Carolina Tax CommissionSupreme Court of the United States · 1932

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3Cited by2 opinions

  1. KSS Transportation Corp. v. BaldwinNew Jersey Tax Court · 1987
  2. Estate of Swensen v. Director, Division of TaxationNew Jersey Tax Court · 1992

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