Legal Opinion
New Jersey Natural Gas Co. v. Director, Division of Taxation
New Jersey Tax Court
Decided April 17, 2008PublishedCited by 5 opinions
1Opinion of the Court
SMALL, P.J.T.C.
Corporations doing business in New Jersey are subject to New Jersey’s Corporation Business Tax. N.J.S.A. 54:10A-1 to -32. If all of a corporation’s activities and property are in New Jersey, 100% of its income is subject to tax in New Jersey. If less than 100% of the corporation’s activities and property are in New Jersey, its income is apportioned to New Jersey under a statutory formula. If the corporation maintains a regular place of business outside of New Jersey, the formula is based on the corporation’s payroll, property and sales inside of New Jersey compared to its…
2Cases cited30 opinions
- Complete Auto Transit, Inc. v. BradySupreme Court of the United States · 1977
- Quill Corp. v. North Dakota Ex Rel. HeitkampSupreme Court of the United States · 1992
- Container Corp. of America v. Franchise Tax BoardSupreme Court of the United States · 1983
- Oklahoma Tax Commission v. Jefferson Lines, Inc.Supreme Court of the United States · 1995
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
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3Cited by5 opinions
- Pfizer Inc. v. Director, Division of TaxationNew Jersey Tax Court · 2008
- Telebright Corp. v. Director, Division of TaxationNew Jersey Tax Court · 2010
- Accuzip, Inc. v. Director, Division of TaxationNew Jersey Tax Court · 2009
- Beljakovic v. DirectorNew Jersey Tax Court · 2012
- Criticare, Inc. v. Director, Division of TaxationNew Jersey Tax Court · 2014