Bombardier Aerospace Corp. v. United States

LESLIE H. SOUTHWICK, Circuit Judge:

Bombardier Aerospace Corporation claims it is not required to remit federal excise tax on fees collected from participants in its fractional-aircraft-ownership program. The district court disagreed and ruled in favor of the Government on cross-motions for summary judgment. We AFFIRM.

FACTS AND PROCEDURAL BACKGROUND

During the successive quarterly tax periods in 2006 and 2007, which are the ones relevant here, Bombardier Aerospace Corporation operated a fractional-aircraft-ownership program called “Flexjet.” Flex-jet participants bought fractional interests in…