Ridgewood Commons Group, LLC v. Director, Division of Taxation

DeALMEIDA, J.T.C.

Plaintiff challenges the Director, Division of Taxation’s calculation of the mansion tax portion of the realty transfer fee on the purchase of two parcels of real property, one subject to the tax and one not, that were transferred by one deed with a single-stated consideration. The Director determined that where a taxpayer elects to combine the consideration for two properties in a single deed without separately stating the amount paid for each property, the mansion tax is properly calculated as a percentage of the entire consideration stated on the deed, even if one of the…