Opinion
Argued June 4, 1985.
Decided June 12, 1985.
Before Judges PRESSLER, BRODY and COHEN.
On appeal from the Tax Court of New Jersey.
Glenn T. Leonard argued the cause for appellant ( Checki Politan, attorneys).
Harry Haushalter argued the cause for respondent ( Irwin I. Kimmelman, Attorney General, attorney; James J. Ciancia, Assistant Attorney General, of counsel).
William S. Robertson, III argued the cause for the amici curiae, Summit Elizabeth Trust Co., New Jersey National Bank, The Ramapo Bank, Pilgrim State Bank, The Chatham Trust Co., Maplewood Bank Trust Co., Ocean County National Bank, Amboy-Madison National Bank and The Town Country Bank ( Williams, Caliri, Miller Otley, attorneys; William S. Robertson, Bruce K. Adler and Carol A. Burns on the brief).
Plaintiff and various amici curiae challenge inclusion in the tax bases of state and federally chartered commercial banks, for the purpose of the New Jersey corporate business tax, of the value of federal, state and local obligations and the income therefrom. After losing in the Tax Court, they appealed here. We are completely satisfied with the determination of the Tax Court and therefore affirm substantially for the reasons expressed by Judge Richard M. Conley in his opinion, reported at 6 N.J. Tax 462 (Tax Ct. 1984).