SCHROEDER, Circuit Judge:
Guam Dai-Ichi Hotel, Inc., real party in interest, appeals the District Court of Guam, Appellate Division's order directing the Guam Superior Court to dismiss Hotel's actions against Guam for tax rebates. We affirm.
The hotel filed the present action in the Superior Court of Guam seeking rebates of territorial income taxes for the tax years 1986 and 1987. Hotel's claim was based on a qualifying certificate issued by the Guam Economic...
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