By Liz Cha and Carley Roberts
The California Court of Appeal held that the entire value of an air taxi company’s jets were subject to the County of Los Angeles 1% personal property tax, despite the fact that the jets spent 40% of their time outside of California. The court reasoned that the brief touchdowns of the jets in out-of-state airports were insufficient for other states to acquire situs over the jets such that California could no longer tax the full value of the aircraft. The court further stated that the landing-based situs rule for aircraft under California Revenue & Tax Code section 1161(b) only applies to fractionally owned aircraft and thus declined to extend this special situs rule to all aircraft. Jetsuite Inc. v. Los Angeles, No. B279273 (2d Dist. 2017).