William Kingsley

Summary

The Court held that a brother of a 10%‑plus stockholder who does not live in the stockholder’s household is not a member of the stockholder’s “immediate family” under N.J.S.A. 54:10A‑4(e). Consequently, the indebtedness owed to the brother’s corporation was not includable in Hawthorne Fabrics’ net worth, and the judgment of the Division of Tax Appeals was affirmed.