Airwork Service Division, a Division of Pacific Airmotive Corporation, a California Corporation, and a Subdivision…

Summary

The Supreme Court of New Jersey affirmed the lower courts, holding that repairs performed in New Jersey on engines destined for out‑of‑state customers are subject to the state sales tax, that equitable estoppel does not bar collection, and that the Director's assessment does not constitute invalid rule‑making under the APA. The Court also rejected the taxpayer's constitutional claims. Justice GARIBALDI, dissenting, argued that the retroactive tax violates fairness and the APA.