Legal Opinion

Bizcap, Inc. v. Olive

Court of Appeals for the Third Circuit

Decided December 29, 1989No. 89-3199PublishedCited by 12 opinions

1Opinion of the Court

OPINION OF THE COURT

MANSMANN, Circuit Judge.

We are faced here with the confusion which results when an erroneously decided opinion is legislatively corrected prior to its ultimate reversal by the court of appeals. Thus, we must decide whether a Virgin Islands corporation, which lobbied for an exception to the Tax Reform Act of 1986, won a hollow victory and found itself, though not liable to the United States Internal Revenue Service for tax on its stateside income, nevertheless liable to the Virgin Islands Bureau of Internal Revenue. We conclude that the exception in § 1277(c)(2)(D) of the…

2Cases cited5 opinions

  1. Caminetti v. United StatesSupreme Court of the United States · 1917
  2. Central Trust Co. v. Official Creditors' Committee of Geiger Enterprises, Inc.Supreme Court of the United States · 1982
  3. Koshatka, Edgar v. Philadelphia Newspapers, Inc. D/B/A the Philadelphia Inquirer and the Daily NewsCourt of Appeals for the Third Circuit · 1985
  4. Danbury, Inc. v. Anthony Olive, Director, Bureau of Internal Revenue, Government of the Virgin IslandsCourt of Appeals for the Third Circuit · 1987
  5. Danbury, Inc. v. OliveDistrict Court, Virgin Islands · 1986

3Cited by12 opinions

  1. Vento v. Director of Virgin Islands Bureau of Internal RevenueCourt of Appeals for the Third Circuit · 2013
  2. Condor Int'l v. CommissionerUnited States Tax Court · 1992
  3. Patrick McGrogan v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2013
  4. Bizcap, Inc. v. OliveCourt of Appeals for the Third Circuit · 1990
  5. Condor Int'l v. CommissionerUnited States Tax Court · 1992

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