The judgment of the Appellate Division is affirmed substantially for the reasons expressed in Judge Smith’s opinion. The Court agrees with the Appellate Division’s assessment that petitioner was never eligible for the exemption under N.J.S.A. 52:14-17.28d(b)(3) and that correcting the erroneous exemption was therefore proper. Neither petitioner’s subsequent service nor his purchase in 2013 of four years of military service credit could change the fact that he did not meet the bright line drawn by the Legislature by June 28, 2011. The Court also agrees with the Appellate Division’s determination that it was not necessary to reach the issue of equitable estoppel, and it offers additional comments on that point.