Legal Opinion

BA Properties Inc. v. Government of the United States Virgin Islands

Court of Appeals for the Third Circuit

Decided July 29, 2002No. 00-2771PublishedCited by 1 opinion

1Opinion of the Court

OPINION OF THE COURT

BECKER, Chief Judge.

This appeal presents a close and difficult question concerning the meaning of an exemption provision in the Virgin Islands Stamp Tax Act. At the first level, resolution of the case requires investigation of the law of real estate financing, with consequent impact on foreclosure practice in the U.S. Virgin Islands. Ultimately, however, the case turns on the application of the rules of construction governing tax exemptions, and particularly the strength of the rule that such exemptions are construed narrowly against the party seeking them.

BA Properties,…

2Cases cited25 opinions

  1. James Callwood v. Jerry Enos , Director, Bureau of Correction Chesley Roebuck, Chairman of V.I. Parole BoardCourt of Appeals for the Third Circuit · 2000
  2. De Castro v. Board of Comm'rs of San JuanSupreme Court of the United States · 1944
  3. Aron Rosenberg v. Xm Ventures, a Maryland Trust and Motient Corporation, a Delaware CorporationCourt of Appeals for the Third Circuit · 2001
  4. Government of the Virgin Islands v. Louis SmithCourt of Appeals for the Third Circuit · 1991
  5. Pension Benefit Guaranty Corporation v. Yahn & McDonnell, Inc.Supreme Court of the United States · 1987

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3Cited by1 opinion

  1. Ba Properties Inc. v. Government Of The United States Virgin IslandsCourt of Appeals for the Third Circuit · 2002

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