New Jersey Entire Net Income Must Reflect ‘Attribute Reduction'

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Robert Willens, president of Robert Willens LLC, examines MCI Commc'n Servs., Inc. v. Dir., Div. of Taxation, in which the New Jersey Tax Court rejected a taxpayer's argument that a reduction of its tax attributes resulting from “pushed-down” cancellation of indebtedness income in its consolidated return group should be ignored for state franchise tax purposes.