Search Rutgers Law Library N.J. Court Opinions

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

... were beyond the statute of limitations for an audit under N.J.S.A. 54:49-6. The court finds that permitting defendant to adjust plaintiff’s ... constitutes an audit of closed years, which is impermissible under N.J.S.A. 54:49-6. Any suggestion that an audit of the closed years would ... such assessment to the taxpayer;” and (3) demand payment. N.J.S.A. 54:49-6(a). However, no “assessment of additional tax” shall be ... from the date of the filing of a return.” N.J.S.A. 54:49-6(b). 5 Here, it is undisputed that at the time ... assess any additional CBT for those years. Per Taxation, therefore, N.J.S.A. 54:49-6(b) is not material to the issue before the court ... audited” after the four-year period. The court finds that N.J.S.A. 54:49-6(a) and (b) must be read together. Subsection (a) ...

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

2 /usr/local/share/www/libweb/collections/courts/tax/19335-10.opn.html -- rank: 948

... such penalty . . . with respect to deficiency assessments made pursuant to [ N.J.S.A. ] 54:49-6.” N.J.S.A. 54:49-11(a). � ...

docket:
court:	NJ Superior Court Law/Chancery Division
decided:
status:
citation:
Document Size:	103902

3 UNITED PARCEL SERVICE GENERAL SERVICES CO. v. DIRECTOR, DIVISION OF TAXATION, -- rank: 802

... in the Law that authorizes the imposition of penalties is N.J.S.A. 54:49-6(a). Under N.J.S.A. 54:49-11a, the ...

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

4 ARTHUR G. NEVINS, JR. v. DIRECTOR, DIVISION OF TAXATION -- rank: 739

... “additional tax” under the State Tax Uniform Procedure Law, N.J.S.A. 54:49-6, or a “[d]eficiency assessment,” where after a ... “The purpose of a notice of deficiency is . . . 15 N.J.S.A. 54 :49-6 permits assessment of “additional tax” under the same circumstances ... penalties, if any, pursuant to any State tax law.” N.J.S.A. 54:49-6. 13 [t]o comply with IRC 6213 . . . [t]o ensure ...

docket:	13075-15
court:	NJ Tax Court
decided:	2019-01-08
status:	Published
citation:
Document Size:	49289

5 /usr/local/share/www/libweb/collections/courts/tax/asd.opn.html -- rank: 739

... they were beyond the statute of limitations for audit under N.J.S.A. 54:49-6. Since the closed tax years were never audited by defendant ... the closed years. This is impermissible and time barred under N.J.S.A. 54:49-6. Defendant’s broad discretion under N.J.S.A. 54 ... nevertheless limited by the four-year statute of limitations under N.J.S.A. 54:49-6. Since the NOL adjustment is time barred, defendant’s cross ...

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

6 ARTHUR G. NEVINS, JR. v. DIRECTOR, DIVISION OF TAXATION -- rank: 737

... “additional tax” under the State Tax Uniform Procedure Law, N.J.S.A. 54:49-6, or a “[d]eficiency assessment,” where after a ... “The purpose of a notice of deficiency is . . . 15 N.J.S.A. 54:49-6 permits assessment of “additional tax” under the same circumstances ... penalties, if any, pursuant to any State tax law.” N.J.S.A. 54:49-6. 13 [t]o comply with IRC 6213 . . . [t]o ensure ...

docket:	ouch
court:	NJ Tax Court
decided:	2019-01-16
status:	Published
citation:
Document Size:	49949

7 /usr/local/share/www/libweb/collections/courts/appellate/00240-15.opn.html -- rank: 722

... taxes where required by law is clearly set forth in N.J.S.A. 54:49-6, entitled, “Examination of return, report; assessment of additional tax ... to any State tax law or pursuant to this subtitle . . . . [N.J.S.A. 54:49-6(a).] The estate tax statute at N.J.S.A ...

docket:
court:	NJ Superior Court Law/Chancery Division
decided:
status:
citation:
Document Size:	130242

8 COMCAST OF SOUTH JERSEY, INC. v. DIRECTOR, DIVISION OF TAXATION -- rank: 714

... by this act. [ N.J.S.A. 54:32B-26.] N.J.S.A. 54:49-6(a) directs that the Director “shall assess” additional taxes ... any penalty . . . with respect to deficiency assessments made pursuant to N.J.S.A. 54:49-6. An abatement will be granted if the taxpayer can show ...

docket:	01153-04
court:	NJ Tax Court
decided:	2012-12-18
status:	unpublished
citation:
Document Size:	71699

9 George V. Richardson v. Dir, Div of Taxation -- rank: 711

... the Act, N.J.S.A. 54:49-4 and N.J.S.A. 54:49-6, pertaining to the assessment of penalties, is to apply "for ...

docket:	05783-93
court:
decided:	1994-12-09
status:
citation:	14 N.J. Tax 356
Document Size:	82346

10 CORALLOS, INC. v. DIRECTOR, DIVISION OF TAXATION -- rank: 694

... making of the assessments had actually run. See , e.g. , N.J.S.A. 54:49-6 b and N.J.S.A. 54:32B-27(b ... of limitations for making assessments would have expired pursuant to N.J.S.A. 54:49-6(b) and N.J.S.A. 54:32B-27(b ... See N.J.S.A. 54:32B-27(b) and N.J.S.A. 54:49-6 b, both providing for a four year statute of limitations ... waited until the audit was complete before finalizing the assessment. N.J.S.A. 54:49-6(a); see also , N.J.S.A. 54:32B-19 ...

docket:	06985-03
court:
decided:	2005-06-13
status:
citation:
Document Size:	47637

11 GODWIN PUMPS OF AMERICA, Plaintiff v. DIRECTOR, DIVISION OF TAXATION, -- rank: 677

... a tax. In support if this contention, taxpayer points to N.J.S.A. 54:49-6(b) and the Tax Court’s opinion in Stewart v ... at 660. Second, the language relied on by taxpayer in N.J.S.A. 54:49-6(b) is inapplicable because it is specifically limited to situations ... tax, it could have easily adopted the language used in N.J.S.A. 54:49-6(b). 1 It did not, however, and its language, coupled ... statute and regulation currently before the court, the purpose of N.J.S.A. 54:49-6(b) is to establish finality in the assessment process through ... shall be considered as filed on such last day.” N.J.S.A. 54:49-6(b). The fact that the Legislature inserted said language into ...

docket:	01789-00
court:
decided:	2001-01-22
status:
citation:	19 N.J. Tax 325
Document Size:	18983

12 United Parcel Serv. Gen. Servs. Co. v. Dir., Div. of Taxation -- rank: 665

... amnesty penalties under the New Jersey Corporation Business Tax Act, N.J.S.A. 54:49-6(a), N.J.S.A. 54:53-17, -18, against ... unpaid taxes on the imputed income, late payment penalties under N.J.S.A. 54:49-6(a), and tax amnesty penalties under N.J.S.A ... amnesty penalties under the New Jersey Corporation Business Tax Act, N.J.S.A. 54:49-6(a), N.J.S.A. 54:53-17, -18, against ...

docket:	A-16-13
court:	NJ Supreme Court
decided:	2014-12-04
status:
citation:	220 N.J. 90 103 A.3d 260
Document Size:	42326

13 E.S.S. Co. v. Director, New Jersey Division of Taxation -- rank: 662

... documents and to assess additional CBT is further detailed in N.J.S.A. 54:49-6 and 54:50-2 (State Uniform Tax Procedure Law), as ... in N.J.S.A. 54:10A-19.1(d). N.J.S.A. 54:49-6 (a) provides: After a return or report is filed under ...

docket:	007589-16
court:	NJ Tax Court
decided:	2021-12-03
status:	Unpublished
citation:
Document Size:	46186

14 SOLVAY SPECIALTY POLYMERS, LLC v. DIRECTOR, DIVISION OF TAXATION -- rank: 651

... conflicts with N.J.S.A. 54:32B-27 and N.J.S.A. 54:49-6 and would permit the collection of additional tax flowing from ...

docket:	009365-19
court:	NJ Tax Court
decided:	2022-01-19
status:	Unpublished
citation:
Document Size:	55941

15 /usr/local/share/www/libweb/collections/courts/tax/00028-14opn.opn.html -- rank: 648

... and 2006 are barred by the statute of limitations under N.J.S.A. 54:49-6(b). The Division concedes that the statute of limitations bars ... N.J.S.A. 54 :10A-1 to -41. 4 N.J.S.A. 54 :49-6(b). 5 The Division argues that the CBT Act permits ...

docket:
court:	NJ Superior Court Law/Chancery Division
decided:
status:
citation:
Document Size:	36781