Legal Opinion
Rupert Brent Johnson and Ada Marie Johnson v. Leroy Quinn, Commissioner, Department of Finance Government of the Virgin Islands
Court of Appeals for the Third Circuit
Decided June 22, 1987No. 86-3461PublishedCited by 8 opinions
1Opinion of the Court
OPINION OF THE COURT
ROSENN, Circuit Judge.
This appeal presents the question whether Virgin Islands residents who have paid income tax to a state of the United States are entitled to a foreign tax credit against their Virgin Islands tax or only to an itemized deduction in calculating their Virgin Islands tax liability. As we agree with the Commissioner that the equality principle of construction of the Virgin Islands “mirror” tax code and Treasury Regulation § 1.901-1(g)(5) compel the conclusion that the taxpayers may claim only a deduction, we affirm the district court’s judgment of…
2Cases cited11 opinions
- Burnet v. Chicago Portrait Co.Supreme Court of the United States · 1932
- George H. T. Dudley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Chicago Bridge and Iron Company, Ltd. v. Ruben B. Wheatley, Commissioner of FinanceCourt of Appeals for the Third Circuit · 1970
- Sayre & Company, Ltd. v. R. A. Riddell, Commissioner of Revenue and TaxationCourt of Appeals for the Ninth Circuit · 1968
- 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
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Chase Manhattan Bank, N.A. v. Government of the Virgin Islands, Bureau of Internal RevenueCourt of Appeals for the Third Circuit · 2002
- WIT Equipment Co. v. Director, Virgin Islands Bureau of Internal RevenueDistrict Court, Virgin Islands · 2001
- Abramson Enterprises, Inc. v. Government of the Virgin IslandsCourt of Appeals for the Third Circuit · 1993
- Abramson Enterprises, Inc. v. Government of the Virgin Islands of the United States Anthony Olive, Director, V.I. Bureau of Internal Revenue, Abramson Enterprises, Inc. v. Government of the V.I. Of U.S. Edward Thomas, Director, V.I. Bureau of Internal Revenue Alexander Farrelly, Governor of the United States Virgin Islands, Edward E. Thomas, Director as Named in No. 1991-289 and as Successor in Office in No. 1989-112, Virgin Islands Bureau of Internal RevenueCourt of Appeals for the Third Circuit · 1993
- Chase Manhattan Bank, N.A. v. Government of the Virgin Islands of the United StatesDistrict Court, Virgin Islands · 2001
3 more not listed; retrieve them via the Exa API.