Legal Opinion
Sayre & Company, Ltd. v. R. A. Riddell, Commissioner of Revenue and Taxation
Court of Appeals for the Ninth Circuit
Decided May 28, 1968No. 20771_1PublishedCited by 22 opinions
1Opinion of the Court
BROWNING, Circuit Judge:
We are called upon again, as we were in Atkins-Kroll (Guam) Ltd. v. Government of Guam, 367 F.2d 127 (1966), to interpret sections 881 and 7701 of the Internal Revenue Code of 1954, 26 U.S.C. §§ 881, 7701 (1964), as applied to Guam by section 31 of the Organic Act of Guam, 64 Stat. 392 (1950), as amended, 72 Stat. 681 (1958), 48 U.S.C. § 1421i (1964).
Upon re-examination of our interpretation of these statutes we have concluded that AtJcins-Ki'oll must be overruled.
Section 31 of the Organic Act, as amended, 48 U.S.C. § 1421i, provides in subsection (a) that the income…
2Cases cited11 opinions
- Finton J. Phelan, Jr., and E. R. Crain v. Richard Taitano and Harry L. MangerichCourt of Appeals for the Ninth Circuit · 1956
- Laguana v. AnsellDistrict Court, D. Guam · 1952
- John Wilson, Leonard White, Paul Bogovich and Elizabeth Tintorri v. B. L. Kennedy, Ford Q. Elvidge, Howard D. Porter and Richard TaitanoCourt of Appeals for the Ninth Circuit · 1956
- Rivera v. BuscagliaCourt of Appeals for the First Circuit · 1944
- Jennings v. United StatesUnited States Court of Claims · 1958
6 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Bank of Guam v. United StatesCourt of Appeals for the Federal Circuit · 2009
- Danbury, Inc. v. Anthony Olive, Director, Bureau of Internal Revenue, Government of the Virgin IslandsCourt of Appeals for the Third Circuit · 1987
- Rea Paeste v. Government of GuamCourt of Appeals for the Ninth Circuit · 2015
- Chicago Bridge and Iron Company, Ltd. v. Ruben B. Wheatley, Commissioner of FinanceCourt of Appeals for the Third Circuit · 1970
- Antonio Gumataotao v. Director of Department of Revenue and TaxationCourt of Appeals for the Ninth Circuit · 2001
17 more not listed; retrieve them via the Exa API.