Today’s decision—on a motion for reconsideration from the Division of Taxation (“Division”)—affirms the court’s previous ruling from February. A copy of the decision is available here.
Background and February Ruling
National Auto Dealers Exchange, L.P. (“NADE”) was a Delaware limited partnership that did business in New Jersey. Its limited partner—Manheim NJ Investments, Inc. (“Manheim”)—consented to nexus with New Jersey. Manheim effectuated its consent by executing Form NJ-1065E (Nonresident Partner’s Statement of Maintaining a Regular Place of Business in New Jersey), a copy of which it provided to NADE. Because it consented to nexus, Manheim directly paid New Jersey income tax on its distributive share of income from the partnership.