United Parcel Service General Services Co. v. Director, Division of Taxation, A-0940-10T3; Appellate Division; opinion by Lihotz, J.A.D.; decided and approved for publication March 7, 2013. On appeal from the Tax Court, Nos. 7845-2004, 7879-2004, 7889-2004, 7890-2004, 7891-2004. [Sat below: Judge Kuskin.] DDS No. 35-2-xxxx [22 pp.]

Plaintiffs are five entities of the United Parcel Service group (UPS Group), each of which is a subsidiary of United Parcel Service of America Inc. (America), the parent corporation. United Parcel Service General Services Co. (GS), UPS Telecommunications Inc. (Telecom), UPS Worldwide Forwarding Inc. (WWF), UPS Worldwide Forwarding Inc. as successor in interest to UPS Air Forwarding Inc. (AF), and United Parcel Service Co. (UPSCO) filed separate complaints in the Tax Court, contesting the Division of Taxation’s assessment of corporate business tax (CBT), pursuant to New Jersey’s Corporation Business Tax Act, N.J.S.A. 54:10A-1 to -41, following an audit.