Opinion
Submitted December 13, 1983.
Decided December 23, 1983.
Before Judges MICHELS, KING and DREIER.
On appeal from the Tax Court of New Jersey.
Lawrence S. Berger attorney for appellant ( Robert A. Bornstein on the brief).
Podvey, Sachs Catenacci, attorneys for respondent ( Robert L. Podvey of counsel; Landis W. Atkinson on the brief).
The judgment of the Tax Court is affirmed for the reasons stated in Judge Hopkins' reported opinion at 5 N.J. Tax 338 (Tax Ct. 1983) and his unreported memorandum opinion of December 3, 1981.