District Court, Virgin Islands July 24, 2003, CIV.A.2001-195, CIV.A.2001-193 (Government of the Virgin Islands v. AT & T of the Virgin Islands, Inc.)

OPINION

PER CURIAM.

I. FACTUAL BACKGROUND

A. AT & T and Caneel Bay

On February 24 and February 25, 1998, the Government of the Virgin Islands, through Lorna Webster [“Webster”] as the director of the Division of Corporations and Trademarks, sent Caneel Bay letters informing that an examination of its franchise tax reports indicated that Caneel Bay had failed to include additional paid-in capital