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NetJets Large Aircraft, Inc. v. U.S.

80 F. Supp. 3d 743 (2015)

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NetJets Large Aircraft, Inc. v. U.S.

United States District Court for the Southern District of Ohio

80 F. Supp. 3d 743 (2015)

Facts

NetJets Large Aircraft, Inc. (NetJets) (plaintiff) provided services to owners of aircrafts. NetJets charged its clients three types of fees: (1) occupational hourly fees related to the use of the aircraft in flight; (2) monthly management fees that covered insurance and labor costs; and (3) variable fuel surcharges if the price of fuel increased beyond a certain price. The Internal Revenue Service (IRS) (defendant) had previously published a technical-advice memorandum (the memorandum) that explained only the hourly fees would be taxed under § 4261 of the Internal Revenue Code. NetJets relied on the memorandum and only paid taxes on its hourly fees. Years later, the IRS assessed a deficiency against NetJets for unpaid taxes on the management fees and fuel surcharges. The IRS had never revoked its earlier memorandum that stated only the hourly fees were subject to taxation. NetJets appealed.

Rule of Law

Issue

Holding and Reasoning (Sargus, C.J.)

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