Search Rutgers Law Library N.J. Court Opinions

1 R.O.P. AVIATION, INC. v. DIRECTOR, DIVISION OF TAXATION -- rank: 1000

... forward NOLs is supported by the broad discretion afforded under N.J.S.A. 54:10A-10, which permits any adjustments in determining the “fair and ... percentage of profit in the years they were incurred (see N.J.S.A. 54:10A-10).” Taxation then issued a Notice of Final Audit determination ... prior returns filed did not reflect arms-length transactions” (citing N.J.S.A. 54:10A-10 and N.J.A.C. 18:7-5.10 as ... 4) Taxation’s Authority to Adjust Carried Forward NOLs Under N.J.S.A. 54:10A-10 N.J.S.A. 54:10A-10 provides Taxation with broad authority to adjust a taxpayer’s ... as to create an improper loss or net income.” N.J.S.A. 54:10A-10(b). Similarly, Taxation “is authorized and empowered” in ...

docket:	1323-18
court:	NJ Tax Court
decided:	2021-05-27
status:	Published
citation:
Document Size:	52044

2 UNITED PARCEL SERVICE GENERAL SERVICES CO. v. DIRECTOR, DIVISION OF TAXATION, -- rank: 983

... The imputation of interest issues involve application and interpretation of N.J.S.A. 54:10A-10 which authorizes the Director to make adjustments in order to ... corporation is subject to the tax imposed by this act. [ N.J.S.A. 54:10A-10.] The issues also involve interpretation of N.J.A.C ... by the Director for purposes of implementing the provisions of N.J.S.A. 54:10A-10. Subparagraphs (a)(1) and (2) of the regulation essentially reiterate ... Subparagraph (a)5 provides in pertinent part as follows: Under N.J.S.A. 54:10A-10(b) interest should be charged on loans or advances made ... on their respective CBT-100 returns, the Director, pursuant to N.J.S.A. 54:10A-10 and N.J.A.C. 18:7-5.10(a ... respect to these loans pursuant to the authority granted by N.J.S.A. 54:10A-10 and N.J.A.C. 18:7-5.10( ...

docket:	07845-04
court:
decided:	2009-06-05
status:
citation:
Document Size:	163074

3 /usr/local/share/www/libweb/collections/courts/tax/15083-14.opn.html -- rank: 904

... argues that N.J.S.A. 54:10A-27 and N.J.S.A. 54:10A-10(a) grant the Division statutory authority to promulgate such restrictive ... N.J.S.A. 54:10A-27, defendant points to N.J.S.A. 54:10A-10 as a source of authority to promulgate the N.J.A.C. �18:7-1.15(b) (9). N.J.S.A. 54:10A-10 grants the Division broad authority to address tax evasion. The ... determination of the amount of tax payable under this act. [ N.J.S.A. 54:10A-10 (2002).] Defendant concedes in its supplemental brief dated August 31 ... N.J.A.C. 18:7-1.15 pursuant to N.J.S.A. 54:10A-10(a) in addition to N.J.S.A. 54:10A-27. However, the Division’s reliance on N.J.S.A. 54:10A-10(a) is misplaced. This section of the Act permits ...

docket:
court:	NJ Superior Court Law/Chancery Division
decided:
status:
citation:
Document Size:	100921

4 /usr/local/share/www/libweb/collections/courts/tax/08253-13.opn.html -- rank: 790

... pursuant to [ N.J.S.A. 54:10A-6 through N.J.S.A. 54:10A-10] . . .” N.J.S.A. 54A:5-10. The referenced ...

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court:	NJ Superior Court Law/Chancery Division
decided:
status:
citation:
Document Size:	44756

5 UNB INVESTMENT COMPANY, INC., Plaintiff, Approved for Publication In the New Jersey Tax Court Reports v. DIRECTOR, DIVISION OF TAXATION, <br -- rank: 758

... Director also maintains that he has sufficient authority pursuant to N.J.S.A. 54:10A-10 to correct the distortion in income resulting from the avoidance ... place pursuant to the authority granted to the Director by N.J.S.A. 54:10A-10 to correct direct or indirect distortions of income. N.J ... forms and instructions provided. I do not wish to read N.J.S.A. 54:10A-10 in a manner which is unduly narrow, because I recognize ... J., concurring) (quoting Director’s brief to the effect that N.J.S.A. 54:10A-10 is applicable where unorthodox business practices of the taxpayer caused ... entire net income cannot, however, be justified by resort to N.J.S.A. 54:10A-10 where the Tax Court had decided Corporate Property Investors , supra ...

docket:	04760-03
court:
decided:	2004-05-12
status:
citation:	21 N.J. Tax 354
Document Size:	61589

6 CHIRON CORPORATION v. DIRECTOR, DIVISION OF TAXATION, -- rank: 684

... the sales fraction and thus plaintiff’s allocation factor. See N.J.S.A. 54:10A-10 (authorizing the Director to adjust entire net income allocable to ...

docket:	00120-99
court:
decided:	2004-11-19
status:
citation:	21 N.J. Tax 528
Document Size:	71168

7 UNITED PARCEL SERVICE GENERAL SERVICES CO. v. DIRECTOR, DIVISION OF TAXATION -- rank: 684

... ascribed no tax consequence to them. On audit, pursuant to N.J.S.A. 54:10A-10 and N.J.A.C. 18:7-5.10(a ...

docket:	a0940-10
court:	NJ Superior Court Appellate Division
decided:	2013-03-07
status:	published
citation:	430 N.J.Super. 1 61 A.3d 160
Document Size:	48481

8 METRO TOUCH, INC., v. DIRECTOR, DIVISION OF TAXATION -- rank: 673

... the issues raised by plaintiff’s appeal are contained in N.J.S.A. 54:10A-10 entitled “Evasion of Tax; adjustments and redetermination; obtaining information ...

docket:	04359-02
court:
decided:	2004-05-10
status:
citation:	21 N.J. Tax 312
Document Size:	18838

9 Stryker Corporation v. Director, Division of Taxation -- rank: 505

... clearly authorized to adjust the allocation of entire net income. N.J.S.A. 54:10A-10. ������������We do not believe that Stryker's business practices are ...

docket:	a-27-00
court:	njsupreme
decided:	2001-06-14
status:
citation:	168 N.J. 138
Document Size:	36989

10 /usr/local/share/www/libweb/collections/courts/tax/asd.opn.html -- rank: 478

... S.A. 54:49-6. Defendant’s broad discretion under N.J.S.A. 54:10A-10 to determine a taxpayer’s fair and reasonable corporation busines ...

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court:	NJ Superior Court Law/Chancery Division
decided:
status:
citation:
Document Size:	28150