MERRILL, Circuit Judge.
This action was brought by appellant in the District Court of Guam against appellee as Guam's Commissioner of Revenue and Taxation for recovery of gross receipts tax in the sum of $766.69, claimed to have been erroneously paid. Appellee counterclaimed for the recovery of additional tax in the sum of $182.72. Judgment of the district court was in favor of appellee, both in the main action and on the counterclaim, and this appeal followed pursuant...
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