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BANK OF AMERICA, NAT. TRUST & SAV. ASS'N v. CHACO

Civ. No. 169-72.

423 F.Supp. 409 (1976)

BANK OF AMERICA, NATIONAL TRUST & SAVINGS ASSOCIATION, a National Bank, Petitioner, v. Manuel A. CHACO, Director of Revenue & Taxation, Government of Guam, (Successor to Joaquin G. Blaz), Respondent.

District Court of Guam.

October 28, 1976.

Attorney(s) appearing for the Case

Walter S. Ferenz, Barrett, Ferenz, Bramhall & Williams, Agana, Guam, for petitioner.

Sidney Manster, Asst. Atty. Gen., of Guam, Agana, Guam, for respondent.

OPINION

DUENAS, District Judge.

On June 6, 1972, Joaquin G. Blaz, Director of Revenue and Taxation of the Government of Guam, hereinafter referred to as "Director", caused to be mailed to Petitioner Bank of America, National Trust & Savings Association, a notice of income tax deficiency in the amount of $537,375.36 for the taxable years ending December 31, 1965, 1966, 1967, and 1968.

Petitioner, in a timely manner, filed the petition at issue...

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