The problem with the deal as far as the Court was concerned is that PB and NJSEA had just done too good a job in eliminating any downside or upside for PB.

FORBES: Pitney Bowes Passes Go From Boardwalk But Lands On Income Tax

As the Court saw it there was simply not a partnership between NJSEA and PB, merely an attempt to transfer the credit.

FORBES: Pitney Bowes Passes Go From Boardwalk But Lands On Income Tax