HAMLEY, Circuit Judge.
In their joint Guam Territorial income tax returns for the years 1957 through 1960, George E. Koster and his wife, Crystal K. Koster, claimed as deductions, mainland United States business losses for those years. Guam tax officials disallowed these deductions, asserting that under applicable regulations, only expenses, losses or other deductions directly attributable to gross income derived from or earned in Guam may be claimed. The taxpayers...
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