
    XCEL CORPORATION, PLAINTIFF-RESPONDENT, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-APPELLANT.
    Superior Court of New Jersey Appellate Division
    Submitted October 4, 1982
    Decided November 10, 1982.
    Before Judges ARD and KING.
    
      
      Irwin I. Kimmelman, Attorney General of New Jersey, attorney for appellant (James J. Ciancia, Assistant Attorney General, of counsel and Harley A. Williams, Deputy Attorney General, on the brief).
    
      McCarter & English, attorneys for respondent (Peter C. Aslanides, of counsel; William T. Reilly and Michael A. Guariglia, on the brief).
   PER CURIAM.

The judgment of the Tax Court is affirmed for the reasons stated in the reported opinion of Judge Conley at 4 N.J.Tax 85 (1982).  