Slater v. Director, Division of Taxation

Plaintiff appeals from a decision of the Tax Court that denied his motion seeking a refund of Sales and Use tax (“S & U”) and *187granted the motion filed by defendant, Director, Division of Taxation (the Director), to dismiss his complaint with prejudice for lack of subject matter jurisdiction. The facts and issues raised by this appeal are set forth in the Tax Court’s published opinion, 26 N.J.Tax 322 (2012), and need not be repeated at length here.

In February 1997, the Director sent plaintiff a Notice of Finding of Responsible Person Status, holding him liable for S & U taxes due and owing…