31 Club, Inc. v. Dir., Div. of Taxation

New Jersey Tax Court·Decided August 8, 2025·No. 011518-2017·Unpublished

Opinion

TAX COURT OF NEW JERSEY

JOSHUA D. NOVIN Dr. Martin Luther King, Jr. Justice Building Judge 495 Dr. Martin Luther King, Jr. Blvd., 4th Floor Newark, New Jersey 07102

Tel: (609) 815-2922, Ext. 54680

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE TAX COURT COMMITTEE ON OPINIONS

July 22, 2025

Ryan S. Curran, Esq. Curran Law Firm 59 Lincoln Park Suite 250 Newark, New Jersey 07102

Heather Lynn Anderson Deputy Attorney General Division of Law R.J. Hughes Justice Complex P.O. Box 106 Trenton, New Jersey 08625-0106

Re: 31 Club, Inc. v. Dir., Div. of Taxation Docket No. 011518-2017

Dear Mr. Curran and Deputy Attorney General Anderson:

This letter shall constitute the court’s opinion on plaintiff’s motion for summary judgment seeking entry of an order awarding attorney’s fees and costs, under N.J.S.A. 54:51A-22; and on the Director’s motion for summary judgment seeking entry of an order enforcing the settlement agreement placed on the record on February 12, 2025.

For the reasons explained more fully below, the plaintiff’s motion is denied and the Director’s motion is granted.

I. Procedural History and Factual Findings Following an audit of 31 Club, Inc. (“plaintiff”), for the tax periods ending December 31, 2010, December 31, 2011, December 31, 2012, and December 31, 2013, the Director, Division of Taxation (the “Director”) asserted deficiencies of Sales and Use Tax, N.J.S.A. 54:32B-1 to 29,

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Corporation Business Tax, N.J.S.A. 54:10A-1 to 41, and Gross Income Tax, N.J.S.A. 54A:1-1 to 12-6, against plaintiff and plaintiff’s shareholders. 1 Thereafter, the plaintiff pursued administrative appeal remedies with the Director’s Conference and Appeals Branch. On May 16, 2017, the Director issued a Final Determination letter finding plaintiff liable for $100,501.80 in deficiencies of Sales and Use Tax, N.J.S.A. 54:32B-1 to 29, Corporation Business Tax, N.J.S.A. 54:10A-1 to 41, and Gross Income Tax, N.J.S.A. 54A:1-1 to 12-6, (the “Final Determination”).

On August 8, 2017, plaintiff filed a complaint with the Tax Court challenging the Director’s Final Determination. The fourth count of plaintiff’s complaint sought “reimbursement of reasonable attorney’s fees on account of [p]laintiff’s assertions of bad faith against it by [d]efendant [Director].”

On February 12, 2025, the court conducted a case management conference on the record (the “Case Management Conference”). Present during the Case Management Conference was plaintiff’s counsel, plaintiff’s managing partner, Michael Fernandez (“Mr. Fernandez”), and the Director’s counsel.

During the Case Management Conference, plaintiff’s counsel and the Director’s counsel reported to the court that the parties had reached an amicable resolution of this litigation. The court then asked plaintiff’s counsel to memorialize the terms of the settlement agreement on the record. In response, plaintiff’s counsel stated the following:

the resolution which was reached by the parties was any Sales or Use tax balance, G[ross] I[ncome] T[ax] balance were zeroed out,

1 Although plaintiff’s complaint asserts that “[p]laintiff was audited for sales tax for the 2009- 2012 tax years,” the court’s review of the “Summary of Additional Tax Due” prepared by the Director’s Cash Audit Supervisor, Christopher Hanley, attached to plaintiff’s complaint, recites that the Sales Tax audit was for the period “01/01/10 to 12/31/13.”

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and effectively zero. Any audit balance would also be rolled over to this zero-dollar settlement . . . and there was money to be applied from one of the shareholders of the plaintiff, in furtherance of reaching that zero-dollar balance.

In response, the Director’s counsel further confirmed the terms of the settlement to the court, stating that:

the Division of Taxation will accept the monies that it has already received from the business, as well as some funds received on the TGI assessment [from the shareholders], in full satisfaction of all business and personal liabilities related to this audit.

Mr. Fernandez acknowledged to the court having heard the terms of the settlement agreement, as recited by plaintiff’s counsel and the Director’s counsel. Moreover, Mr. Fernandez confirmed to the court that as managing member he was authorized to enter in the settlement on behalf of plaintiff.

Importantly, in response to the court’s inquiry whether he understood “the terms of the proposed resolution that has been memorialized by Mr. Curran . . . today, and confirmed by Deputy Attorney General Anderson,” Mr. Fernandez replied, “it was broad.” Accordingly, the court then inquired whether Mr. Fernandez had any other understanding about the terms of the settlement, thus affording him the opportunity to identify or set forth any additional specific terms, agreement, or provisions regarding the settlement, to which Mr. Fernandez responded, “I agree to zero.” In response, the court confirmed with Mr. Fernandez that, “all the monies that have already been collected by the Division of Taxation by or on behalf of 31 Club Inc., as well as monies that are in receipt of the Director, Division of Taxation from certain shareholders for purposes of Gross Income Tax would then result in a zero balance, that’s your understanding.” Mr. Fernandez then responded to the court, “yes, that’s my understanding.”

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Moreover, the court further confirmed with Mr. Fernandez that the plaintiff entered into the settlement agreement freely and voluntarily. The court further advised Mr. Fernandez that although the Director approved the settlement, the settlement was subject to further approval by the New Jersey Attorney General, which could take several months to obtain. The court then asked Mr. Fernandez if he “was willing to proceed with the settlement agreement upon the terms that have been outlined by the Deputy Attorney General and [plaintiff’s] counsel and as set forth in court here today.” In response, Mr. Fernandez recited “Yes, your honor.”

This matter was subsequently listed for the court’s May 8, 2025 telephone conference call calendar. During the May 8, 2025 telephone conference, plaintiff’s counsel and the Director’s counsel reported to the court that they had reached an impasse regarding a provision under the proposed Stipulation of Dismissal. Specifically, the provision at issue addressed plaintiff’s waiver of any claim for attorney’s fees against the defendant. Accordingly, on May 8, 2025, the court entered a Case Management Order (the “Case Management Order”).

The Case Management Order scheduled an August 25, 2025 peremptory trial date in this matter. In addition, the Case Management Order afforded either party the right to move for entry of an order granting summary judgment, under R. 4:46-1, no later than Thursday, June 19, 2025.

On June 19, 2025, plaintiff filed the instant motion for summary judgment seeking entry of an order awarding plaintiff attorney’s fees and costs, under N.J.S.A. 54:51A-22. In support of its motion to “[a]ward reimbursement of legal fees and costs in the amount $25,000 or an amount deemed just under N.J.S.A. 54:51A-22,” plaintiff asserts that it is entitled to attorney’s fees in this matter because “the State’s [audit] position was ‘without reasonable basis in fact or law.’”

In response to plaintiff’s motion, the Director argues that the proposed settlement and its willingness to accept monies already collected from plaintiff and its shareholders in full

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