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OVERSEAS INNS S.A. P.A. v. U.S.

Civ. A. No. CA3-87-0007-D.

685 F.Supp. 968 (1988)

OVERSEAS INNS S.A. P.A., Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, N.D. Texas, Dallas Division.

May 11, 1988.

Attorney(s) appearing for the Case

Jimmy L. Heisz of Haynes & Boone, Dallas, Tex., for plaintiff.

Cynthia E. Childress, Tax Div., Dept. of Justice, Dallas, Tex., for defendant.

MEMORANDUM OPINION AND ORDER

FITZWATER, District Judge.

The court is asked to accord comity to a Luxembourg court judgment that would permit plaintiff to satisfy a U.S. income tax obligation by paying 23.49% of the taxes owed. Because the court concludes that recognizing such a decree would run counter to U.S. public policy, the court declines to accord comity to the Luxembourg judgment and denies plaintiff's motion for summary judgment.

I.

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