Imaging Services, Inc. v. Oklahoma Tax Commission

HARGRAVE, Justice.

We granted certiorari to review memorandum opinion of the Court of Appeals, Division I, affirming Tax Commission’s assessment of excise tax on transfer of title to aircraft to corporation as trustee on behalf of the owners. The question is whether the transfer of title by the limited partnership to the general partner, a corporation, as trustee, in order to comply with FAA registration requirements, was a taxable transfer of legal ownership under the Aircraft Excise Tax Act, 68 O.S. § 6001 et seq. We hold that it was not.

The facts are stipulated. In November, 1986,…