Legal Opinion
Flight Options, LLC v. Department of Revenue
Washington Supreme Court
Decided August 25, 2011No. 84207-8PublishedCited by 13 opinions
1Opinion of the CourtOwens, J.
¶1 Flight Options LLC challenges the constitutional and statutory authority of the Department of Revenue (Department) to assess apportioned property taxes against the fleet of airplanes it manages. Specifically, Flight Options argues that its airplanes do not have a tax situs in Washington and that the due process clause, U.S. Const, amend. XIV, therefore prohibits assessment of taxes on them. Flight Options further contends that chapter 84.12 RCW prohibits the tax assessment because Flight Options is not an “airplane company” within the statutory definition, because the property has not…
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