Charles E. Smith Management, Inc. v. Department of Taxation

In this case, we determine the validity of a tax assessment imposed pursuant to Code § 58.1-1502 on a non-resident owner of a large private aircraft hangared at Washington National Airport (National Airport), which is a federal enclave.

The facts of the case are not in dispute. Charles E. Smith Management, Inc. (CES) is a District of Columbia corporation with its principal place of business in Arlington County. Since 1990, CES has hangared and maintained an aircraft at National Airport. The purchase of the aircraft and all other transactions related thereto occurred outside the Commonwealth.

On…