United Air Lines, Inc. v. Porterfield

We affirm the decision of the Board of Tax Appeals.

The Privilege Concept

E. C. 5745.02, in pertinent part, provides: ‘ ‘ * * * an ex-cisc- tax is hereby imposed upon the privilege of engaging in the business of transporting persons or property by air within this state.” Appellant, for one of its contentions, seeks to persuade us to view this language as evi*100denting an attempt to Jay a tax on the hare privilege of engaging in interstate commerce, citing Spector Motor Service v. O’Connor (1951), 340 U. S. 602, 609. If the scope of the inquiry were so mundane, our rationale would lie complete, and…