This appeal presents a narrow question: whether, in the circumstances presented, an
out-of-state taxpayer is liable for New Jersey's corporate business tax for the years
1994-1996. The Director of the Division of Taxation asserted, and the Tax Court agreed, ...
Plaintiff, Praxair Technology, Inc. (PTI), a Delaware corporation with its 739 principal place of
business in Connecticut, appeals from the Tax Court's June 27, 2007 order granting partial summary
judgment to defendant, the Director of the Division of Taxation (the Director), regarding ...
I make the following factual findings. Plaintiffs are New Jersey residents and the principals of
some 75 to 100 partnerships and limited liability companies having interests in a large number
of residential and commercial income producing properties. Among plaintiffs' partnership ...