
    HOSPITAL PORTRAIT SERVICE COMPANY, PLAINTIFF-APPELLANT, v. DEPARTMENT OF TREASURY, DIVISION OF TAXATION, DEFENDANT-RESPONDENT.
    Superior Court of New Jersey Appellate Division
    Argued December 11, 1984
    Decided December 21, 1984.
    Before Judges ANTELL, J.H. COLEMAN and SIMPSON.
    
      G. Stephen Ingram argued the cause for appellant (Ingram & Kelley, attorneys; G. Stephen Ingram on the brief).
    
      Martin L. Wheelwright, Deputy Attorney General, argued the cause for respondent (Irwin I. Kimmelman, Attorney General of New Jersey, attorney; James J. Ciancia, Assistant Attorney General of counsel and Martin L. Wheelwright on the brief).
   PER CURIAM.

The determination under review is affirmed substantially for the reasons given by Judge Andrew in his opinion of December 19, 1983, for the Tax Court, 6 N.J.Tax 305 (Tax Ct.1983).  