John L. MANNING, and Carlyn T. Manning, husband and wife, Petitioners-Appellees,
v.
Joaquin G. BLAZ, Director of Revenue and Taxation Government of Guam, Defendant-Appellant.
GENERAL INSURERS, INC., Petitioner-Appellee,
v.
Joaquin G. BLAZ, Commissioner of Revenue and Taxation, Respondent-Appellant.
United States Court of Appeals, Ninth Circuit.https://leagle.com/images/logo.png
April 5, 1973.
Rehearing and Rehearing Denied July 5, 1973.
Attorney(s) appearing for the Case
David Carmack (argued), Dept. of Justice, Washington, D. C., Vincent T. Ferez, Atty. Gen., Gerald E. Stinson, Asst. Atty. Gen., Agana, Guam, for defendant-appellant.
W. S. Barrett (argued), Barrett, Ferenz & Bramhall, Agana, Guam, for petitioners-appellees.
David English Carmack, U. S. Atty. (argued), Scott P. Crampton, Asst. Atty. Gen., Tax Div., Dept. of Justice, Washington, D. C., for amicus curiae.
David English Carmack, U. S. Atty. (argued), Dept of Justice, Washington, D. C., Gerald E. Stinson, Asst. Atty. Gen., Agana, Guam, for respondent-appellant.
W. S. Barrett (argued) Barrett, Ferenz & Bramhall, Agana, Guam; Thomas J. Nolan, Agana, Guam, for petitioner-appellee.
Before CHAMBERS, ELY, and WALLACE, Circuit Judges.
United States Court of Appeals, Ninth Circuit.
Rehearing and Rehearing En Banc Denied July 5, 1973.
PER CURIAM:
These appeals involve the applicability of certain sections of the Internal Revenue Code to transactions which have their taxable locus in Guam. By virtue of the Organic Act of Guam,1 Congress gave Guam a tax structure of its own, patterned closely after the tax system of the United States, but with collections made by and revenues going to the government of Guam...
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