Reuben H. Donnelley Corp. v. Director, Division of Taxation

The opinion of the court was delivered by

DREIER, J.A.D.

Plaintiff, The Ruben H. Donnelley Corp., appeals from a summary judgment entered in the Tax Court determining that *257the value of property owned by Donnelley, subject to (federal) “safe-harbor lease” deductions, was to be excluded from Donnelley’s personal property included in the corporation business tax valuation formula under N.J.S.A. 54:10A-6. There is no dispute as to any material fact concerning the amounts of property owned subject to a safe-harbor lease;1 both sides agreed that only a legal determination was required by the Tax…