Government Of Guam v. Superior Court Of Guam

998 F.2d 754 GOVERNMENT OF GUAM; Joaquin Blaz, Director, Dept. of Revenue & Taxation, Petitioners-Appellees, v. SUPERIOR COURT OF GUAM, Respondent, Guam Dai-Ichi Hotel, Inc., Real Party In Interest-Appellant. No. 92-15060. United States Court of Appeals, Ninth Circuit. Argued and Submitted June 17, 1993. Decided July 14, 1993. David W. Dooley, Carlsmith, Ball, Wichman, Murray, Case, Mukai & Ichiki, Agana, Guam, and Donn Dimichele, Carlsmith, Ball, Wichman, Murray, Case, Mukai & Ichiki, Los Angeles, CA, for real party in interest-appellant. David C. Sullivan, Asst. Atty. Gen., Agana, Guam, for petitioners-appellees. Appeal from the United States District Court for the District of Guam, Appellate Division. Before: LAY, * HUG, and SCHROEDER, Circuit Judges. SCHROEDER, Circuit Judge: 1 Guam Dai-Ichi Hotel, Inc., real party in interest, appeals the District Court of Guam, Appellate Division's order directing the Guam Superior Court to dismiss Hotel's actions against Guam for tax rebates. We affirm. 2 The hotel filed the present action in the Superior Court of Guam seeking rebates of territorial income taxes for the tax years 1986 and 1987. Hotel's claim was based on a…