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JENNINGS v. UNITED STATES

Nos. 390-56, 5-57, 102-57.

155 F.Supp. 571 (1957)

Lloyd Lester JENNINGS et al. v. The UNITED STATES. Benjamin R. ANDERSON et al. v. The UNITED STATES. Reginald A. BAKER et al. v. The UNITED STATES.

United States Court of Claims.

October 9, 1957.

Attorney(s) appearing for the Case

Thomas M. Gittings, Jr., Washington, D. C., John W. Gaskins and King & King, Washington, D. C., on the briefs, for plaintiffs.

Sheldon J. Gitelman, Washington, D. C., with whom was Charles K. Rice, Asst. Atty Gen., James P. Garland and George Willi, Washington, D. C., on the briefs, for defendant.

Before JONES, Chief Judge, and LITTLETON, WHITAKER, MADDEN and LARAMORE, Judges.

LITTLETON, Judge.

Plaintiffs brought this action against the United States to recover income taxes for the tax years 1951-1954, inclusive, which taxes are alleged to have been illegally assessed and collected by the Government of Guam acting on the advice of and pursuant to the direction of the Commissioner of Internal Revenue of the United States.

Prior to 1950, little or no federal income taxes were paid on income derived from sources within Guam, because...

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