EDWARD L. MCMENAMY AND MARGARET MCMENAMY, PLAINTIFFS-APPELLANTS, v. DIRECTOR, DIVISION OF TAXATION, DEFENDANT-RESPONDENT

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).