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DAVID R. ALLEN, PLAINTIFF-RESPONDENT, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-APPELLANT.

PER CURIAM.

The judgment of the Tax Court, whose opinion is reported at 14 N.J. Tax 385 (Tax Court 1994), is affirmed substantially for the reasons stated by Judge Small.

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ALLEN v. DIRECTOR, DIVISION OF TAXATION
(Mar 5, 1996)