FEDERAL JURISDICTION FOR TAX CHALLENGE UPHELD

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March 2, 2003 – A U.S. 3rd Circuit Court of Appeals judicial panel has rejected the V.I. government's argument that a lawsuit in District Court challenging the territory's manner of assessing commercial properties for tax purposes should be thrown out because the federal court lacks jurisdiction in the matter.
The three-judge panel ruled that the plaintiff, Equivest St. Thomas Inc., "properly alleged a violation of a federal requirement." Equivest is the corporate owner of three St. Thomas hotels — Bluebeard's Castle, Bluebeard's Beach Club (once known at Limetree) and Elysian Beach Resort.
The Circuit Court opinion was filed on Friday, the same day that Gov. Charles W. Turnbull announced his signing into law of a bill calling for commercial property taxes to be assessed for 2001 through 2004 on the basis of 1999 valuations. (See "Governor signs special session bills into law".)
The appellate opinion upholds the authority of District Judge Thomas K. Moore, who is currently hearing a consolidated case of 11 property owners challenging the V.I. government's tax assessments for 2000 on the same basis as that argued by Equivest, and before that, by Berne Corp.
In the landmark case brought against the V.I. government in District Court by St. Thomas businessman Gary Berne, a settlement was reached in December 2000 calling for a Special Master to be appointed to oversee reforms in the Tax Collector's Office. The terms of the settlement were sealed. However, Tax Assessor Roy Martin has said he cannot implement the reforms without a bigger budget.
The case brought by Bluebeard's Castle Inc. and Castle Acquisitions Inc., which were later consolidated into Equivest, advanced the same argument as Berne had: challenging the government's assessing of commercial property for 2000 tax purposes on the basis of replacement value, not actual market value. The government's total assessment of the properties was $98.4 million, resulting in a tax bill of about $740,000. They had been appraised independently in 1999 for $38.2 million and actually sold that year for $22.5 million.
In the Equivest case, Moore issued a preliminary injunction last year to prevent the territory from collecting property taxes against the three hotels "until the tax assessor can establish at a trial on the merits that the property taxes on those properties have been assessed on their actual value."
The Circuit Court of Appeals opinion was rendered by Judges Samuel A. Alito Jr., Marjorie Rendell and Anthony Joseph Scirica. Nandi Sekou and Kerry Drue of the Attorney General's Office represented the V.I. government. Simone R.D. Francis, Chad C. Messier and William S. McConnell of Dudley Topper and Feuerzeig represented Equivest.
In their opinion, the jurists said the appeal involved their addressing "the special relationship between federal and territorial law." They wrote: "The District Court enjoined the Virgin Islands tax assessor from employing a certain tax-assessment method, concluding it violated federal law. Contending that any claims can only arise under territorial law, the government of the Virgin Islands maintains the District Court lacked federal subject-matter jurisdiction. We hold that plaintiff has properly pled a federal claim."
The V.I. government also argued in its appeal that Moore abused his discretion in rejecting its argument that the injunction should be denied because Equivest had "failed to pursue avenues for relief within the Virgin Islands and insufficiently cooperated with Virgin Islands officials." The appellate panel found "no abuse of discretion."
The opinion notes that the V.I. government "does not contest the District Court's resolution of the merits" of the Equivest lawsuit. It also states that Martin said the territory "primarily employed replacement-cost value and declaration value in assessing the properties, methods he conceded do not reflect fair market value."
Equivest also contends that the government is in breach of the Berne case settlement.
The panel affirmed Moore's preliminary injunction and remanded the case back to District Court for further proceedings.
Amid ongoing cases, a new law
Meanwhile, on Feb. 19, in court for the consolidated case of the 11 property owners, Moore took issue with Turnbull's submitting of his bill to proceed with tax assessments using the 1999 valuations. All of the cases challenging the government's assessment procedures have to do with 2000 property taxes. Moore accused the governor of seeking to circumvent his order against issuing any more tax bills until the current challenge is adjudicated.
In the first week of February, Turnbull called the Legislature into special session to act on his bill to assess commercial properties for 2001-2004 on the basis of 1999 valuations, and on Feb. 12 the Senate passed the measure. That's the bill the governor signed last week.
The governor cited an opinion from Attorney General Iver Stridiron that if the law were to be changed as Turnbull proposed, "there would be no violation of the current settlement agreement, and the government would still be able to continue … sending out corrected commercial real property tax bills until such time as new guidelines are implemented."
Last November, the governor told the Senate that "no 2001 commercial real property tax bills have been issued by the tax assessor due to concern that the court case V.I. Berne Corp. et al. vs. the Government of the V.I. prohibited the government from issuing tax bills until such time as the tax assessor develops and correctly implements uniform appraisal standards."
Martin said last September that his office would have to reassess all commercial properties because of a ruling by Moore in August that some 25 commercial property owners did not have to meet the Aug. 30 deadline for paying their 2001 taxes pending the court's determination of whether those bills were proper. Martin said then that his office was working on the reappraisals, to apply to 2002 taxes, and that what to do regarding the 2001 taxes "hasn't been decided."
In July, Martin had testified at a budget hearing that tax revenues for the territory's 1,500 commercial properties assessed on the basis of replacement value would be $9 million to $10 million for 2002, but based on market value, they could be as little as $7 million.
A "hybrid federal/territorial" tax system
The Circuit Court opinion noted that property taxes are generally governed by state law but further noted that "the Virgin Islands is not a state; it is a territory subject to Congress's broad power" under the Constitution to govern territories. And as a territory, it "does not share with the states the same sovereign independence."
Were it a state, the judges said, "the District Court may have been subject to" federal law providing that "the district courts shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under state law where a plain, speedy and efficient remedy may be had in the courts of such state."
Specifically, in 1936 Congress provided that "all taxes on real property in the Virgin Islands shall be computed on the basis of the actual value of such property" and also that they be uniformly assessed. (Historically, the appellate opinion states, Congress took the action "to replace a system viewed as encouraging unproductive use of land" by taxing such land at a very low rate. "It was thought that federal legislation was needed, as the local legislature was unlikely to pass a change to a value-based tax system," the jurists wrote.)
Federal statute, the circuit panel said, provides that "the general requirements are set by the federal government, with specifi cs established as a matter of territorial law consistent with federal law."
The V.I. government argued that the federal statute was supplanted in 1955 when a territorial real property assessment law was passed. The appellate panel rejected this argument, saying expiratory language in the 1936 law applies only to specific requirements, not to general ones, including that tax be computed on the "actual value" of property. "Congress's intent to enter this area of law suffers from no ambiguity," the jurists said.
Further, they said, "the tax system is not a state tax system, nor is it entirely a territorial tax system. It is partially a federal tax system, and it is not apparent that the federal government should adopt a hands-off approach to the federal aspects of a hybrid federal/territorial system."
But at the same time, they said, it has been the choice of Congress "to treat Virgin Islands law — including its taxation regime — with much of the independence of state law."
Equivest's case is properly before the federal court, the panel said, not because it is protesting the government's "actual value" dollar figure but because it is arguing that "the assessment method does not constitute a reasonable attempt to determine the actual value."
Publisher's note : Like the St. Croix Source now? Find out how you can love us twice as much — and show your support for the islands' free and independent news voice … click here.

FEDERAL JURISDICTION FOR TAX CHALLENGE UPHELD

0
March 2, 2003 – A U.S. 3rd Circuit Court of Appeals judicial panel has rejected the V.I. government's argument that a lawsuit in District Court challenging the territory's manner of assessing commercial properties for tax purposes should be thrown out because the federal court lacks jurisdiction in the matter.
The three-judge panel ruled that the plaintiff, Equivest St. Thomas Inc., "properly alleged a violation of a federal requirement." Equivest is the corporate owner of three St. Thomas hotels — Bluebeard's Castle, Bluebeard's Beach Club (once known at Limetree) and Elysian Beach Resort.
The Circuit Court opinion was filed on Friday, the same day that Gov. Charles W. Turnbull announced his signing into law of a bill calling for commercial property taxes to be assessed for 2001 through 2004 on the basis of 1999 valuations. (See "Governor signs special session bills into law".)
The appellate opinion upholds the authority of District Judge Thomas K. Moore, who is currently hearing a consolidated case of 11 property owners challenging the V.I. government's tax assessments for 2000 on the same basis as that argued by Equivest, and before that, by Berne Corp.
In the landmark case brought against the V.I. government in District Court by St. Thomas businessman Gary Berne, a settlement was reached in December 2000 calling for a Special Master to be appointed to oversee reforms in the Tax Collector's Office. The terms of the settlement were sealed. However, Tax Assessor Roy Martin has said he cannot implement the reforms without a bigger budget.
The case brought by Bluebeard's Castle Inc. and Castle Acquisitions Inc., which were later consolidated into Equivest, advanced the same argument as Berne had: challenging the government's assessing of commercial property for 2000 tax purposes on the basis of replacement value, not actual market value. The government's total assessment of the properties was $98.4 million, resulting in a tax bill of about $740,000. They had been appraised independently in 1999 for $38.2 million and actually sold that year for $22.5 million.
In the Equivest case, Moore issued a preliminary injunction last year to prevent the territory from collecting property taxes against the three hotels "until the tax assessor can establish at a trial on the merits that the property taxes on those properties have been assessed on their actual value."
The Circuit Court of Appeals opinion was rendered by Judges Samuel A. Alito Jr., Marjorie Rendell and Anthony Joseph Scirica. Nandi Sekou and Kerry Drue of the Attorney General's Office represented the V.I. government. Simone R.D. Francis, Chad C. Messier and William S. McConnell of Dudley Topper and Feuerzeig represented Equivest.
In their opinion, the jurists said the appeal involved their addressing "the special relationship between federal and territorial law." They wrote: "The District Court enjoined the Virgin Islands tax assessor from employing a certain tax-assessment method, concluding it violated federal law. Contending that any claims can only arise under territorial law, the government of the Virgin Islands maintains the District Court lacked federal subject-matter jurisdiction. We hold that plaintiff has properly pled a federal claim."
The V.I. government also argued in its appeal that Moore abused his discretion in rejecting its argument that the injunction should be denied because Equivest had "failed to pursue avenues for relief within the Virgin Islands and insufficiently cooperated with Virgin Islands officials." The appellate panel found "no abuse of discretion."
The opinion notes that the V.I. government "does not contest the District Court's resolution of the merits" of the Equivest lawsuit. It also states that Martin said the territory "primarily employed replacement-cost value and declaration value in assessing the properties, methods he conceded do not reflect fair market value."
Equivest also contends that the government is in breach of the Berne case settlement.
The panel affirmed Moore's preliminary injunction and remanded the case back to District Court for further proceedings.
Amid ongoing cases, a new law
Meanwhile, on Feb. 19, in court for the consolidated case of the 11 property owners, Moore took issue with Turnbull's submitting of his bill to proceed with tax assessments using the 1999 valuations. All of the cases challenging the government's assessment procedures have to do with 2000 property taxes. Moore accused the governor of seeking to circumvent his order against issuing any more tax bills until the current challenge is adjudicated.
In the first week of February, Turnbull called the Legislature into special session to act on his bill to assess commercial properties for 2001-2004 on the basis of 1999 valuations, and on Feb. 12 the Senate passed the measure. That's the bill the governor signed last week.
The governor cited an opinion from Attorney General Iver Stridiron that if the law were to be changed as Turnbull proposed, "there would be no violation of the current settlement agreement, and the government would still be able to continue … sending out corrected commercial real property tax bills until such time as new guidelines are implemented."
Last November, the governor told the Senate that "no 2001 commercial real property tax bills have been issued by the tax assessor due to concern that the court case V.I. Berne Corp. et al. vs. the Government of the V.I. prohibited the government from issuing tax bills until such time as the tax assessor develops and correctly implements uniform appraisal standards."
Martin said last September that his office would have to reassess all commercial properties because of a ruling by Moore in August that some 25 commercial property owners did not have to meet the Aug. 30 deadline for paying their 2001 taxes pending the court's determination of whether those bills were proper. Martin said then that his office was working on the reappraisals, to apply to 2002 taxes, and that what to do regarding the 2001 taxes "hasn't been decided."
In July, Martin had testified at a budget hearing that tax revenues for the territory's 1,500 commercial properties assessed on the basis of replacement value would be $9 million to $10 million for 2002, but based on market value, they could be as little as $7 million.
A "hybrid federal/territorial" tax system
The Circuit Court opinion noted that property taxes are generally governed by state law but further noted that "the Virgin Islands is not a state; it is a territory subject to Congress's broad power" under the Constitution to govern territories. And as a territory, it "does not share with the states the same sovereign independence."
Were it a state, the judges said, "the District Court may have been subject to" federal law providing that "the district courts shall not enjoin, suspend or restrain the assessment, levy or collection of any tax under state law where a plain, speedy and efficient remedy may be had in the courts of such state."
Specifically, in 1936 Congress provided that "all taxes on real property in the Virgin Islands shall be computed on the basis of the actual value of such property" and also that they be uniformly assessed. (Historically, the appellate opinion states, Congress took the action "to replace a system viewed as encouraging unproductive use of land" by taxing such land at a very low rate. "It was thought that federal legislation was needed, as the local legislature was unlikely to pass a change to a value-based tax system," the jurists wrote.)
Federal statute, the circuit panel said, provides that "the general requirements are set by the federal government, with specific s established as a matter of territorial law consistent with federal law."
The V.I. government argued that the federal statute was supplanted in 1955 when a territorial real property assessment law was passed. The appellate panel rejected this argument, saying expiratory language in the 1936 law applies only to specific requirements, not to general ones, including that tax be computed on the "actual value" of property. "Congress's intent to enter this area of law suffers from no ambiguity," the jurists said.
Further, they said, "the tax system is not a state tax system, nor is it entirely a territorial tax system. It is partially a federal tax system, and it is not apparent that the federal government should adopt a hands-off approach to the federal aspects of a hybrid federal/territorial system."
But at the same time, they said, it has been the choice of Congress "to treat Virgin Islands law — including its taxation regime — with much of the independence of state law."
Equivest's case is properly before the federal court, the panel said, not because it is protesting the government's "actual value" dollar figure but because it is arguing that "the assessment method does not constitute a reasonable attempt to determine the actual value."
Publisher's note : Like the St. John Source now? Find out how you can love us twice as much — and show your support for the islands' free and independent news voice … click here.

GET INTO MARCH WITH SOME EATIN' O' THE GREEN

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March 2, 2003 – If months were known by color, March would surely be green. That's the color of spring on the U.S. mainland, the color of Ireland celebrated on the St. Patrick's Day holiday, and the color of many of those veggies (and even a few fruits) that come to mind when thinking about good nutrition.
As luck would have it, March is National Nutrition Month. So, here's a green recipe — for Broccoli and Avocado Salad — to start off the month.
Broccoli is a relatively recent addition to Virgin Islanders' diet, within the last century. This relative of the cabbage, Brussels sprouts and cauliflower is native to Italy. It's available fresh year 'round in supermarkets. Look for broccoli with florets that have a deep green color and are crisp. For best keeping, refrigerate fresh broccoli unwashed in an airtight bag. Broccoli is a high-nutrition veggie, packed with vitamins A and C, riboflavin, calcium, iron and disease-preventing phytonutrients.
Avocados are native to the tropics and grow on trees throughout the Caribbean. The green-skinned Fuerte avocado is found locally more often than the almost black, rough-skinned Haas, which is grown almost exclusively in California. Known for their rich, buttery texture, avocados are high in calories and fat –although this fat is in a heart-healthy mono-unsaturated form.
Enjoy broccoli and avocado in tandem in this salad. Accented with a squeeze of lemon and an oil-and-vinegar dressing spiked with garlic, these green ingredients make a delicious as well as nutritious dish.
Broccoli and Avocado Salad
1 small bunch of fresh broccoli
Salt to taste
1 large ripe avocado
1/2 of a fresh lemon
1 teaspoon Dijon-style mustard
1/2 teaspoon finely chopped garlic
1 tablespoon red wine vinegar
Freshly ground black pepper, to taste
3 tablespoons extra virgin olive oil
Cut the broccoli into florets. Drop florets into enough boiling salted water to cover them. Bring to a boil and cook 2 minutes. Drain; run the broccoli briefly under cold water to cool. Drain again and chill.
Cut the avocado in half. Peel each half and remove the pit. Cut each half into 8 lengthwise strips. Squeeze the lemon half over the strips to prevent discoloration.
Arrange the broccoli florets and and the avocado strips alternately on each of four serving plates.
In a bowl, blend the mustard, garlic, vinegar, pepper and oil, adding salt if desired with a wire whisk. Pour over the broccoli and avocado. Serve immediately.
Serves 4. Per serving: 162 calories, 15 gms fat (74 percent fat calories), no cholesterol, 174 mg sodium.

Publisher's note : Like the St. Croix Source now? Find out how you can love us twice as much — and show your support for the islands' free and independent news voice … click here.

GET INTO MARCH WITH SOME EATIN' O' THE GREEN

0
March 2, 2003 – If months were known by color, March would surely be green. That's the color of spring on the U.S. mainland, the color of Ireland celebrated on the St. Patrick's Day holiday, and the color of many of those veggies (and even a few fruits) that come to mind when thinking about good nutrition.
As luck would have it, March is National Nutrition Month. So, here's a green recipe — for Broccoli and Avocado Salad — to start off the month.
Broccoli is a relatively recent addition to Virgin Islanders' diet, within the last century. This relative of the cabbage, Brussels sprouts and cauliflower is native to Italy. It's available fresh year 'round in supermarkets. Look for broccoli with florets that have a deep green color and are crisp. For best keeping, refrigerate fresh broccoli unwashed in an airtight bag. Broccoli is a high-nutrition veggie, packed with vitamins A and C, riboflavin, calcium, iron and disease-preventing phytonutrients.
Avocados are native to the tropics and grow on trees throughout the Caribbean. The green-skinned Fuerte avocado is found locally more often than the almost black, rough-skinned Haas, which is grown almost exclusively in California. Known for their rich, buttery texture, avocados are high in calories and fat –although this fat is in a heart-healthy mono-unsaturated form.
Enjoy broccoli and avocado in tandem in this salad. Accented with a squeeze of lemon and an oil-and-vinegar dressing spiked with garlic, these green ingredients make a delicious as well as nutritious dish.
Broccoli and Avocado Salad
1 small bunch of fresh broccoli
Salt to taste
1 large ripe avocado
1/2 of a fresh lemon
1 teaspoon Dijon-style mustard
1/2 teaspoon finely chopped garlic
1 tablespoon red wine vinegar
Freshly ground black pepper, to taste
3 tablespoons extra virgin olive oil
Cut the broccoli into florets. Drop florets into enough boiling salted water to cover them. Bring to a boil and cook 2 minutes. Drain; run the broccoli briefly under cold water to cool. Drain again and chill.
Cut the avocado in half. Peel each half and remove the pit. Cut each half into 8 lengthwise strips. Squeeze the lemon half over the strips to prevent discoloration.
Arrange the broccoli florets and and the avocado strips alternately on each of four serving plates.
In a bowl, blend the mustard, garlic, vinegar, pepper and oil, adding salt if desired with a wire whisk. Pour over the broccoli and avocado. Serve immediately.
Serves 4. Per serving: 162 calories, 15 gms fat (74 percent fat calories), no cholesterol, 174 mg sodium.

Publisher's note : Like the St. John Source now? Find out how you can love us twice as much — and show your support for the islands' free and independent news voice … click here.

GET INTO MARCH WITH SOME EATIN' O' THE GREEN

0
March 2, 2003 – If months were known by color, March would surely be green. That's the color of spring on the U.S. mainland, the color of Ireland celebrated on the St. Patrick's Day holiday, and the color of many of those veggies (and even a few fruits) that come to mind when thinking about good nutrition.
As luck would have it, March is National Nutrition Month. So, here's a green recipe — for Broccoli and Avocado Salad — to start off the month.
Broccoli is a relatively recent addition to Virgin Islanders' diet, within the last century. This relative of the cabbage, Brussels sprouts and cauliflower is native to Italy. It's available fresh year 'round in supermarkets. Look for broccoli with florets that have a deep green color and are crisp. For best keeping, refrigerate fresh broccoli unwashed in an airtight bag. Broccoli is a high-nutrition veggie, packed with vitamins A and C, riboflavin, calcium, iron and disease-preventing phytonutrients.
Avocados are native to the tropics and grow on trees throughout the Caribbean. The green-skinned Fuerte avocado is found locally more often than the almost black, rough-skinned Haas, which is grown almost exclusively in California. Known for their rich, buttery texture, avocados are high in calories and fat –although this fat is in a heart-healthy mono-unsaturated form.
Enjoy broccoli and avocado in tandem in this salad. Accented with a squeeze of lemon and an oil-and-vinegar dressing spiked with garlic, these green ingredients make a delicious as well as nutritious dish.
Broccoli and Avocado Salad
1 small bunch of fresh broccoli
Salt to taste
1 large ripe avocado
1/2 of a fresh lemon
1 teaspoon Dijon-style mustard
1/2 teaspoon finely chopped garlic
1 tablespoon red wine vinegar
Freshly ground black pepper, to taste
3 tablespoons extra virgin olive oil
Cut the broccoli into florets. Drop florets into enough boiling salted water to cover them. Bring to a boil and cook 2 minutes. Drain; run the broccoli briefly under cold water to cool. Drain again and chill.
Cut the avocado in half. Peel each half and remove the pit. Cut each half into 8 lengthwise strips. Squeeze the lemon half over the strips to prevent discoloration.
Arrange the broccoli florets and and the avocado strips alternately on each of four serving plates.
In a bowl, blend the mustard, garlic, vinegar, pepper and oil, adding salt if desired with a wire whisk. Pour over the broccoli and avocado. Serve immediately.
Serves 4. Per serving: 162 calories, 15 gms fat (74 percent fat calories), no cholesterol, 174 mg sodium.

Publisher's note : Like the St. Thomas Source now? Find out how you can love us twice as much — and show your support for the islands' free and independent news voice … click here.

LAST NIGHT FOR THE TENT BIBLE SEMINARS

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March 2, 2003 – The "Breath of Life" telecast has been presenting international evangelist Walter L. Pearson Jr. in a series of Bible seminars.
The final event is to be at 7:15 p.m. Saturday, April 12, at the big yellow and white tent at Lockhart Garden, site of the former Grand Union supermarket.
For more information call Mrs. Benjamin at 774-2988 daytimes. For transportation call 775-1388.

BIBLE SEMINARS START, WILL GO TO APR. 12

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March 2, 2003 – The "Breath of Life" telecast is presenting international evangelist Walter L. Pearson Jr. in a series of Bible seminars on St. Thomas from March 21 through April 12.
The events will be held at 7:15 p.m., nightly except Mondays and Thursdays, at the big yellow and white tent at Lockhart Garden, site of the former Grand Union supermarket.
The topic for opening night, Friday, March 21, is "Oh, Mary, Oh, Martha." For more information call Mrs. Benjamin at 774-2988 daytimes.
For transportation call 775-1388.

BIBLE SEMINARS SET NIGHTLY MARCH 21-APRIL 12

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March 2, 2003 – The "Breath of Life" telecast is presenting international evangelist Walter L. Pearson Jr. in a series of Bible seminars on St. Thomas from March 21 through April 12.
The events will be held at 7:15 p.m., nightly except Mondays and Thursdays, at the big yellow and white tent at Lockhart Garden, site of the former Grand Union supermarket.
The topic for opening night, Friday, March 21, is "Oh, Mary, Oh, Martha." For more information call Mrs. Benjamin at 774-2988 daytimes.
For transportation call 775-1388.

Publisher's note : Like the St. Thomas Source now? Find out how you can love us twice as much — and show your support for the islands' free and independent news voice … click here.

FLIGHT 64 ROAD RACE SET FOR MARCH 9

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March 2, 2003 — The Flight 64 Four Mile Road Race will be held at 6 a.m. Sunday, March 9. The race will start and finish near the St. Croix airport parking lot exit to Melvin Evans Highway.
All are invited to participate. The entry fee is $5, and the entry form is online at the link below.
Awards will go to top finishers, male and female, in the "Run Like the Wind" series. Today's race is the fourth and final race in the V.I. Pace Runners "Run Like the Wind" road race series.
For more information call V.I. Pace Runners at 777-0258 or logon to virginislandspace.org.

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UVI OPEN HOUSE FOR HIGH SCHOOLS

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UVI will host an Open House for high school seniors and juniors, and school officials on Friday, March 7, from 9:30 a.m. to 3 p.m. at the UVI Sports and Fitness Center on the St. Thomas campus.
UVI faculty, staff and students will be on hand to answer questions and provide perspective on the unique UVI experience. Informational sessions and a Fair Exhibition are scheduled from 9:30 a.m. to noon. Lunch is slated from noon to 1 p.m. and campus tours will be offered 1 p.m. to 3 p.m.
For more information contact UVI's office of student recruitment at 693-1224.