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SAYRE & COMPANY v. RIDDELL

No. 20771.

395 F.2d 407 (1968)

SAYRE & COMPANY, Ltd., Appellant, v. R. A. RIDDELL, Commissioner of Revenue and Taxation, Appellee.

United States Court of Appeals Ninth Circuit.

May 28, 1968.

Attorney(s) appearing for the Case

W. Scott Barrett (argued), David S. Madis, of Barrett, Ferenz & Trapp, Oakland, Cal., and Agana, Guam, for appellant.

Olen Burnett (argued), Deputy Atty. Gen., Harold Burnett, Atty. Gen., C. E. Morrison, Asst. Atty. Gen., Agana, Guam; J. Edwin Shillingburg, Atty., Dept. of Justice, Washington, D. C., for appellee.

Before CHAMBERS, BARNES, HAMLEY, MERRILL, KOELSCH, BROWNING, DUNIWAY, ELY and CARTER, Circuit Judges.

BROWNING, Circuit Judge:

We are called upon again, as we were in Atkins-Kroll (Guam) Ltd. v. Government of Guam, 367 F.2d 127 (1966), to interpret sections 881 and 7701 of the Internal Revenue Code of 1954, 26 U.S.C. §§ 881, 7701 (1964), as applied to Guam by section 31 of the Organic Act of Guam, 64 Stat. 392 (1950), as amended, 72 Stat. 681 (1958), 48 U.S.C. § 1421i (1964).

Upon re-examination of our interpretation...

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