Opinion
Argued December 6, 1982.
Decided December 29, 1982.
Appeal from the Tax Court.
Before Judges MILMED, MORTON I. GREENBERG and FURMAN.
Gerald C. Neary argued the cause for plaintiffs-appellants ( Pitney, Hardin, Kipp Szuch, attorneys; Gerald C. Neary, on the initial and reply briefs).
Mary R. Hamill, Deputy Attorney General, argued the cause for defendant-respondent ( Irwin I. Kimmelman, Attorney General of New Jersey, attorney; James J. Ciancia, Assistant Attorney General of counsel; Mary R. Hamill, on the brief).
The judgment under review is affirmed substantially for the reasons expressed by Judge Hopkins in his opinion for the Tax Court of September 25, 1981, reported at 3 N.J. Tax 356 (Tax Ct. 1981).