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MILLER v. QUINN

No. 85-3353.

792 F.2d 392 (1986)

Gregory E. MILLER and Doris D. Miller v. Leroy A. QUINN, Director of Internal Revenue, Appellant.

United States Court of Appeals, Third Circuit.

Decided June 12, 1986.

Rehearing and Rehearing Denied July 15, 1986.

Attorney(s) appearing for the Case

Meno W. Piliaris (argued) Asst. Atty. Gen. (Tax), Dept. of Law, Government of the Virgin Islands, Christiansted, St. Croix, V.I., for appellant.

Gregory E. Miller (argued), Christiansted, St. Croix, V.I., for appellees.

Before HUNTER, WEIS, and MANSMANN, Circuit Judges.

Rehearing and Rehearing In Banc Denied July 15, 1986.

OPINION OF THE COURT

JAMES HUNTER, III, Circuit Judge:

Leroy A. Quinn, the Director of the Virgin Islands Bureau of Internal Revenue ("Director"), appeals the district court's grant of a petition to redetermine a tax deficiency brought by joint filers Gregory E. Miller and Doris D. Miller. Subject matter jurisdiction before the District Court of the Virgin Islands was based on V.I.Code Ann. tit...

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