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AFFILIATED DEVELOPMENT CORP. v. OLIVE

No. 89-3183.

893 F.2d 647 (1990)

AFFILIATED DEVELOPMENT CORP., Appellant v. Anthony P. OLIVE, Director of Virgin Islands Bureau of Internal Revenue, and Government of the Virgin Islands, Appellees.

United States Court of Appeals, Third Circuit.

Decided January 12, 1990.

Attorney(s) appearing for the Case

Gustav A. Danielson (argued), Charlotte Amalie, St. Thomas U.S. V.I., for appellant.

Godfrey R. de Castro, Atty. Gen., Rosalie Simmonds Ballentine, Sol. Gen., Joanne E. Bozzuto (argued), Asst. Atty. Gen. (Tax), Government of the Virgin Islands, Dept. of Justice, St. Thomas, V.I., for appellees.

Before GIBBONS, Chief Judge, and MANSMANN and NYGAARD, Circuit Judges.

OPINION OF THE COURT

PER CURIAM.

Affiliated Development Corp., a Virgin Islands inhabitant foreign corporation, appeals from a judgment affirming deficiencies in income tax for the years ending November 30, 1982 and November 30, 1983, a penalty under 26 U.S.C. § 6661 for the year ending November 30, 1983, negligence penalties under 26 U.S.C. § 6653(a) for both years, and late filing penalties under 26 U.S.C. § 6051 for both years. The legal...

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