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Constitutional Law Keyed to Choper
Massachusetts v. United States
Citation:
435 U.S. 444 (1978)Facts
The Commonwealth of Massachusetts owned and operated a helicopter that was used exclusively for police functions. The federal government imposed an annual registration tax on all civil aircraft, including the state’s helicopter, under the Airport and Airway Revenue Act of 1970. This tax was part of a comprehensive scheme to recoup the costs of federal aviation programs and services. Massachusetts paid the tax under protest and then sued for a refund, claiming that the tax violated the implied constitutional immunity of state governments from federal taxation. The state argued that since the helicopter was used solely for essential police functions, it should be exempt from federal taxation under the principle of intergovernmental tax immunity. The United States defended the tax as a legitimate user fee that applied uniformly to all aircraft benefiting from federal aviation services.
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