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O'CONNOR v. UNITED STATES

No. 85-558.

479 U.S. 27 (1986)

O'CONNOR ET UX. v. UNITED STATES

Supreme Court of United States.

Decided November 4, 1986

Attorney(s) appearing for the Case

Carter G. Phillips argued the cause for petitioners in all cases. On the briefs were Andrew C. Barnard, David J. Kiyonaga, Allan I. Mendelsohn, Marvin I. Szymkowicz, John C. Morrison, George S. Barnard, Michael C. Pierce, and Dwight A. McKabney.

Jerrold J. Ganzfried argued the cause for the United States. With him on the brief were Solicitor General Fried, Assistant Attorney General Olsen, Deputy Solicitor General Wallace, Michael L. Paup, David English Carmack, and Abraham D. Sofaer.

JUSTICE SCALIA delivered the opinion of the Court.

The petitioners, United States citizen employees of the Panama Canal Commission and their spouses, seek refunds of income taxes collected on salaries paid by the Commission between 1979 and 1981. We granted certiorari to resolve conflicting appellate interpretations of an international agreement. 474 U.S. 1050 (1986).

From 1904 to 1979, the United States exercised sovereignty over the Panama Canal and the...

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