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JOHN RECK and BARBARA RECK, Plaintiffs-Appellants, v. DIRECTOR,DIVISION OF TAXATION, Defendant-Respondent.

PER CURIAM

The judgment is affirmed, substantially for the reasons expressed in Judge Stern's opinion of the Appellate Division, reported at 345 N.J. Super. 443 (2001).

CHIEF JUSTICE PORITZ and JUSTICES COLEMAN, LaVECCHIA, ZAZZALI and ALBIN join in this opinion. JUSTICES LONG and VERNIERO filed a separate dissenting opinion.

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RECK v. DIVISION OF TAXATION
(Dec 19, 2002)