Shell Oil Co. v. United States

This case, before the court on stipulated facts, presents a novel question concerning the application of the excise tax on air transportation to helicopter service. It arises out of contractual arrangements by which the charge for helicopter service comprises both an hourly rate for actual use of the helicopter and a monthly charge which guarantees the user the availability of a helicopter upon demand. The issue is whether the tax is imposed upon both elements of the total charge (as the Commissioner of Internal Revenue applied it) or only upon the portion of the charge covering the use of…