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FLIGHT OPTIONS v. STATE, DEPT. OF REVENUE

No. 39517-7-II.

225 P.3d 354 (2010)

FLIGHT OPTIONS LLC, Appellant, v. STATE of Washington, DEPARTMENT OF REVENUE, Respondent.

Court of Appeals of Washington, Division 2.

January 12, 2010.

Attorney(s) appearing for the Case

Scott M. Edwards, Perkins Coie LLP, Seattle, WA, Travis a Exstrom, Attorney at Law, Seattle, WA, for Appellant.

Brett S. Durbin, Heidi A. Irvin, Atty. General's Office-Revenue Div., Olympia, WA, for Respondent.

HOUGHTON, J.

¶ 1 Flight Options LLC appeals the trial court's order granting summary judgment in favor of the Department of Revenue (DOR) on its tax assessment. Flight Options argues that DOR improperly assessed the tax against it because, among other reasons, it does not own the assessed property. We disagree and affirm.

FACTS

¶ 2 Flight Options sells fractional interests in jet aircraft that it manages, staffs, and operates from its principal...

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