
    DAVID R. ALLEN, PLAINTIFF-RESPONDENT, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-APPELLANT.
    Superior Court of New Jersey Appellate Division
    Argued February 21, 1996
    Decided March 5, 1996.
    Before Judges PRESSLER and A.A. RODRIGUEZ.
    
      Joseph Fogelson, Deputy Attorney General, argued the cause for appellant (Deborah T. Poritz, Attorney General, attorney; Joseph L. Yannotti Assistant Attorney General, of counsel; Mr. Fogelson, on the brief).
    
      
      David R. Allen, appellant, appeared pro se.
   PER CURIAM.

The judgment of the Tax Court, whose opinion is reported at 14 N.J. Tax 385 (Tax Court 1994), is affirmed substantially for the reasons stated by Judge Small.  