TOYOTA MOTOR CREDIT CORPORATION v. DIRECTOR, DIVISION OF TAXATION

NOT FOR PUBLICATION WITHOUT THE

APPROVAL OF THE APPELLATE DIVISION

This opinion shall not "constitute precedent or be binding upon any court." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY

APPELLATE DIVISION

DOCKET NO. A-0

TOYOTA MOTOR CREDIT

CORPORATION,

Plaintiff-Respondent,

v.

DIRECTOR, DIVISION OF

TAXATION,

Defendant-Appellant.

______________________________

October 23, 2017

Argued October 12, 2017 Decided

Before Judges Haas, Rothstadt and Gooden Brown.

On appeal from the Tax Court of New Jersey, Docket No. 2021-2010, whose opinion is reported at 28 N.J. Tax 96 (Tax Ct. 2014).

Michael J. Duffy, Deputy Attorney General, argued the cause for appellant (Christopher S. Porrino, Attorney General, attorney; Melissa H. Raksa, Assistant Attorney General, of counsel; Mr. Duffy, on the brief).

Kyle O. Sollie argued the cause for respondent (Reed Smith, LLP, attorneys; Mr. Sollie, of counsel and on the brief; Kenneth R. Levine, on the brief).

PER CURIAM

The June 5, 2015 judgment is affirmed substantially for the reasons expressed in Judge Patrick DeAlmeida's August 1, 2014 opinion reported at 28 N.J. Tax 96 (Tax Ct. 2014).