New Jersey Tax Court July 17, 2014 (De Rosa v. Director, Division of Taxation)

BIANCO, J.T.C.

This opinion constitutes the court’s decision with respect to the Motion for Summary Judgment filed by defendant, Director of the Division of Taxation (the “Director”), and the Cross-Motion for Summary Judgment filed by plaintiff, Peter De Rosa (“Mr. De Rosa”), as the Executor of the Estate of Joseph Rendeiro, (“the *75Estate”).