
    EDWARD L. MCMENAMY AND MARGARET MCMENAMY, 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.
    
      Gerald C. Neary argued the cause for plaintiffs-appellants (Pitney, Hardin, Kipp & Szuch, attorneys; Gerald C. Neary, 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 Hopkins in his opinion for the Tax Court of September 25, 1981, reported at 3 N.J.Tax 356 (Tax Ct.1981).  