Legal Opinion
Abramson Enterprises, Inc. v. Government of the Virgin Islands
Court of Appeals for the Third Circuit
Decided May 28, 1993No. Civil No. 89-00112; Civil No. 91-00289; No. 92-7381PublishedCited by 6 opinions
1Opinion of the Court
OPINION OF THE COURT
GARTH, Circuit Judge
This appeal concerns the narrow question of whether the corporate surtax imposed on Virgin Islands taxpayers pursuant to V.I. Code Ann. tit. 33, § 581 (Supp. 1990) ("§ 581") is deductible from Virgin Islands taxable income under § 164 of the Internal Revenue Code ("§ 164") as applied to the Virgin Islands under the "mirror system" of taxation. We conclude that the surtax is non-deductible and, accordingly, we will reverse the judgment of the district court and direct that judgment be entered in favor of the Virgin Islands Bureau of Internal Revenue.
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2Cases cited3 opinions
- 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
- Rupert Brent Johnson and Ada Marie Johnson v. Leroy Quinn, Commissioner, Department of Finance Government of the Virgin IslandsCourt of Appeals for the Third Circuit · 1987
3Cited by6 opinions
- Vento v. Director of Virgin Islands Bureau of Internal RevenueCourt of Appeals for the Third Circuit · 2013
- Patrick McGrogan v. Commissioner of Internal RevenCourt of Appeals for the Third Circuit · 2013
- 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
- Group v. United States Virgin IslandsDistrict Court, Virgin Islands · 2012
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