Opinion
Submitted December 23, 1981.
Decided January 12, 1982.
Appeal from the Tax Court of New Jersey.
Woodcock McClure, for appellant ( Joseph C. Woodcock, Jr. on the letter brief).
Joseph S. Seidel, for respondent ( Joseph S. Seidel on the letter brief).
Before Judges FRITZ and TRAUTWEIN.
The decision of the Tax Court, 2 N.J. Tax 421, is affirmed substantially for the reasons expressed in its letter opinion of March 23, 1981 granting summary judgment in favor of the defendant.
Affirmed.