Bank of Guam v. United States

MEMORANDUM OPINION AND ORDER

CHRISTINE O.C. MILLER, Judge.

Since 1978 Bank of Guam (“plaintiff’) has purchased and held certain United States Government obligations (“USGOs”), including bonds and Treasury bills from the United States. In 2001 the Guam Department of Revenue and Taxation (the “GDRT”) issued a Notice of Deficiency to plaintiff for the tax years 1992, 1993, and 1994 due to plaintiffs failure to pay any Guam Territorial income tax (the “GTIT”) on its interest income from USGOs. Plaintiff alleges that the USGOs purchased and held constituted contracts with the United States…