BANK OF GUAM v. U.S.

Attorney(s) appearing for the Case

Kurt W. Melchior, Nossaman LLP, of San Francisco, CA, argued for plaintiff-appellant. With him on the brief was Robert M. Adler, Nossaman LLP/O'Connor & Hannan, of Washington, DC. Of counsel on the brief were Jerome Sapiro, Jr. and David A. Sauers, The Sapiro Law Firm, of San Francisco, CA.

Brian A. Mizoguchi, Trial Attorney, Commercial Litigation Branch, Civil Division, United States Department of Justice, of Washington, DC, argued for defendant-appellee. With him on the brief was Jeanne E. Davidson, Director. Of counsel on the brief was Cleve Lisecki, Attorney-Advisor, Office of the Associate Chief Counsel (International), Internal Revenue Service, of Washington, DC.

Before LOURIE, SCHALL, and GAJARSA, Circuit Judges.