Checkpoint Contents Federal Library Federal Source Materials IRS Rulings & Releases Private Letter Rulings & TAMs, FSAs, SCAs, CCAs, GCMs, AODs & Other FOIA Documents Chief Counsel Advice 2012 CCA 201210026 -- Code Sec(s). 4261, 03/09/2012 CCA 201210026 UIL No. 4261.00-00Excise taxes—transportation of persons by air—aircraft management fees. Headnote: Control of aircraft's pilots is factor for determining person who has possession, command and control of aircraft, and management has possession, command and control of aircraft in all of 3 described scenarios. And, monthly management fees, as well as separately reimbursed amounts, paid to management in each of 3 scenarios are "amounts paid for taxable air transportation" of persons, and thus are taxable under IRC Sec(s). 4261 Reference(s): IRC Sec(s). 4261 FULL TEXT: Number: 201210026 Release Date: 3/9/2012 CC:PSI:B07:MHBeker POSTN-148348-11 EFTA00584985