We affirm substantially for the reasons stated by Judge Andrew in his opinion for the Tax Court of August 4, 1981, reported at 3 N.J.Tax 105, 437 A.2d 353 (Tax Ct.1981).
We affirm substantially for the reasons stated by Judge Andrew in his opinion for the Tax Court of August 4, 1981, reported at 3 N.J.Tax 105, 437 A.2d 353 (Tax Ct.1981).