Summary
concluding that a subsequent purchaser of property was not an aggrieved taxpayer as of the April 1st deadline for filing a tax appeal "within the meaning of N.J.S.A. 54:3-21 because, as of such date, it had no interest in the subject property and no obligation to pay property taxes assessed to the property."
Summary of this case from Procacci Bros. Sales Corp. v. DirectorOpinion
Argued Telephonically April 17, 1997
Decided May 9, 1997
On Appeal from the Tax Court of New Jersey.
Before Judges PETRELLA and KIMMELMAN.
Steven R. Irwin argued the cause for intervenor ( Mandelbaum Mandelbaum, P.A., attorneys; Mr. Irwin, of counsel; Alan Vuernick, on the brief).
Edward M. Dunne argued the cause for respondent Mansfield Township ( Valentino, Dunne Stein, P.C., attorneys; Mr. Dunne, of counsel and on the brief).
Kenneth R. Kosco argued the cause for respondent Mobil Administrative Services Co. ( Garippa Davenport, P.C., attorneys; Mr. Kosco, of counsel and on the brief).
Appellant Zeta Consumer Products Corporation appeals from the denial of its application made to the Tax Court to intervene in pending litigation contesting the tax assessment of property the appellant had purchased. Appellant was held to have lacked the requisite standing to intervene as required by R. 4:33-1.
We affirm substantially for the reasons expressed by Judge Kuskin in his thorough and well-reasoned opinion reported at 15 N.J.Tax 583 (Tax Ct. 1996).