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BANK OF AMERICA, NAT'L TRUST & SAV. ASS'N v. CHACO

No. 74-2978.

539 F.2d 1226 (1976)

BANK OF AMERICA, NATIONAL TRUST & SAVINGS ASSOCIATION, Petitioner-Appellant, v. Manuel A. CHACO, Director of Revenue and Taxation, Government of Guam, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Rehearing and Rehearing Denied October 28, 1976.

Attorney(s) appearing for the Case

Walter S. Ferenz (argued), of Barrett, Ferenz, Baramhall & Klemm, Agana, Guam, for petitioner-appellant.

Philip Howard Jacobsen, Asst. Atty. Gen. (argued), Agana, Guam, for respondent-appellee.

Before BROWNING and KENNEDY, Circuit Judges, and WONG, District Judge.

Rehearing and Rehearing En Banc Denied October 28, 1976.

OPINION

PER CURIAM:

Appellant Bank of America contends that since it is compelled to pay the Guam territorial income tax as imposed by § 31 of the Organic Act of Guam, 64 Stat. 392 (1950), 48 U.S.C. § 1421i, the additional burden of the 4% net profits tax imposed by the Government of Guam as a business privilege tax (Guam Government Code...

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