Texaco Inc. v. Director

LASSER, P.J.T.C.

Taxpayer, Texaco, Inc. seeks to set aside that portion of the final determination of tax liability of the Director of the Division of Taxation under the Corporation Business Tax Act for calendar *573years 1973 through 1978, which imposes interest on a tax deficiency of $578,394 for the period after April 15, 1981, on the ground that taxpayer’s tax liability was fully satisfied by an overpayment of $2,348,606 on April 15,1981. Taxpayer and Director have filed cross motions for summary judgment and partial summary judgment, respectively.1

The facts are not in issue. The legal issue…