
    STANLEY C. SMOYER AND BARBARA B. SMOYER, PLAINTIFFS-APPELLANTS, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-RESPONDENT.
    Superior Court of New Jersey Appellate Division
    Argued December 6, 1982
    Decided December 29, 1982.
    Before Judges MILMED, MORTON I. GREENBERG and FURMAN.
    
      Edward A. Zmz, Jr. argued the cause for plaintiffs-appellants (Riker, Danzig, Scherer & Hyland, attorneys; Edward A. Zunz, Jr. of counsel; J. Ferd Convery, III, on the initial and reply briefs).
    
      Mary R. Hamill, Deputy Attorney General, argued the cause for defendant-respondent (Irwin I. Kimmelman, Attorney General of New Jersey, attorney; James J. Ciancia, Assistant Attorney General, of counsel; Mary R. Hamill, on the brief).
    
   PER CURIAM.

The judgment under review is affirmed substantially for the reasons expressed by Judge Lasser in his opinion for the Tax Court of January 8, 1982, reported at 4 N.J. Tax 42 (Tax Ct.1982).  