
    SILENT HOIST & CRANE CO., INC., PLAINTIFF-RESPONDENT, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-APPELLANT.
    Superior Court of New Jersey Appellate Division
    Argued March 19, 1984
    Decided April 4, 1984.
    Before Judges BISCHOFF, PETRELLA and BRODY.
    
      Mary R. Hamill, Deputy Attorney General, argued the cause for appellant (Irwin I. Kimmelman, Attorney General of New Jersey, attorney; James J. Ciancia, Assistant Attorney General, of counsel).
    
      Daniel E. Horgan argued the cause for respondent (Waters, McPherson, McNeill, P.A., attorneys).
   PER CURIAM.

The Director, Division of Taxation appeals the determinations of the Tax Court which held in favor of the taxpayer as to the nonapplicability of the New Jersey Corporation Business Tax (N.J.S.A. 54:10A-1, et seq.).

We affirm substantially for the reasons expressed in Judge Evers’ opinion reported at 5 N.J.Tax 242 (Tax Ct.1983).  