PER CURIAM.
The Director, Division of Taxation appeals the determinations of the Tax Court which held in favor of the taxpayer as to the nonapplicability of the New Jersey Corporation Business Tax (N.J.S.A. 54:10A-1, et seq.). We affirm substantially for the reasons expressed in Judge Evers’ opinion reported at 5 N.J.Tax 242 (Tax Ct.1983).