
    SCOTT APPLESTEIN, PLAINTIFF-APPELLANT, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-RESPONDENT.
    Superior Court of New Jersey Appellate Division
    Argued February 23, 1984
    Decided March 30, 1984.
    Before Judges FURMAN and DEIGHAN.
    
      
      Edward M. Bernstein argued the cause for appellant (Levy, Levy & Albert, attorneys).
    
      Mary R. Hamill, Deputy Atty. Gen., argued the cause for respondent (Irwin I. Kimmelman, Atty. Gen. of N.J., attorney; James J. Ciancia, Asst. Atty. Gen., of counsel).
   PER CURIAM.

We affirm substantially for the reasons stated by Judge Conley in his opinion reported at 5 N.J.Tax 73 (1982).  