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HOTELS OF MARIANAS, INC. v. GOVERNMENT OF GUAM

No. 94-16413.

71 F.3d 1455 (1995)

HOTELS OF the MARIANAS, INC., d/b/a Hilton International Guam, Plaintiff-Appellee, v. GOVERNMENT OF GUAM, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided December 5, 1995.

Attorney(s) appearing for the Case

Stephen A. Cohen, Assistant Attorney General, Agana, Guam, for defendant-appellant.

Phillip Torres, Gale & Teker, Agana, Guam, for plaintiff-appellee.

Before: HUG, THOMPSON and O'SCANNLAIN, Circuit Judges.

Opinion by Judge THOMPSON.

DAVID R. THOMPSON, Circuit Judge:

The Government of Guam (Guam) appeals the district court's grant of summary judgment in favor of Hotels of the Marianas (Guam Hilton). The dispute is over the amount of rebate due the Guam Hilton on taxes payable to Guam on corporate income for tax years 1986 through 1990.

Pursuant to a statutory scheme designed to promote investment in Guam, the Governor of Guam (Governor) issued Qualifying...

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