Opinion
Argued October 24, 1983 —
Decided December 28, 1983.
Appeal from Superior Court, Appellate Division.
Gerald C. Neary argued the cause for appellants ( Pitney, Hardin, Kipp Szuch, attorneys).
Mary R. Hamill, Deputy Attorney General, argued the cause for respondent ( Irwin I. Kimmelman, Attorney General of New Jersey, attorney; James J. Ciancia, Assistant Attorney General, of counsel).
The judgment of the Appellate Division is affirmed, substantially for the reasons expressed in the opinion of the Tax Court, reported at 3 N.J. Tax 356 (Tax Ct. 1981).
For affirmance — Chief Justice WILENTZ and Justices CLIFFORD, HANDLER, POLLOCK and O'HERN — 5.
For reversal — None.