The New Jersey Tax Court ruled for Toyota Motor Credit Corp. on three issues for New Jersey Corporate Business Tax purposes. Specifically, the court upheld the taxpayer’s gain calculation method using an upwardly adjusted federal tax basis; upheld the taxpayer’s departure from federal bonus depreciation rules; and set aside the Division’s application of the throwout rule to the taxpayer’s receipts for tax years 2003-2006. The taxpayer operated a vehicle leasing business whereby it leased vehicles to consumers and sold the used vehicles after the lease period ended. On the gain calculation issue, the court analogized the taxpayer’s case to a prior decision, Moroney v. Director, Div. of Taxation, 376 N.J. Super. 1 (App. Div. 2005), and ruled the gain from the sale of used vehicles could be calculated using a tax basis upwardly adjusted for depreciation deductions taken for federal tax purposes. On the decoupling issue, the court held that the Division’s regulation constituted an unreasonable exercise of authority because it limited the State’s decoupling provision to property acquired after January 1, 2002 for a fiscal year beginning on or after January 1, 2002, whereas the governing statute states that New Jersey’s decoupling provisions apply to property acquired after September 10, 2001 and before September 11, 2004. On the throwout issue, the court determined that the Division could not “throw out” receipts sourced to Nevada, South Dakota and Wyoming from the taxpayer’s receipts factor denominator because it had sufficient contacts with each state to merit the inclusion of such receipts. The court noted the taxpayer had paid tax to Nevada on its lease receipts and that such fact was irrelevant to whether the tax was on the taxpayer’s business activity or a sales tax. The court also ruled the taxpayer had a sufficient in-state presence in South Dakota and Wyoming through its in-state property or payroll. This case provides helpful guidance for taxpayers seeking either to compute gains using a non-federal tax basis or to defend against the Division’s throwout adjustments for prior tax years. Toyota Motor Credit Corp. v. Dir., Div. of Taxation, Dkt. No. 002021-2010 (Aug. 1, 2014).