Hangar Property Taxes by State: Who Taxes a Hangar on Leased Airport Land

You built a hangar on ground you do not own, at an airport owned by a city, a county, or an authority. The land underneath you is exempt from property tax. Every year some owners in that position get a tax bill and some do not, and the difference is almost never explained. This article answers the question state by state, from the statutes themselves.

Five ways a state reaches a hangar

Begin with the fork that governs everything downstream. Because the land is publicly owned and exempt, the assessor must decide what, if anything, is left in private hands. Across these fifteen states the answer takes one of five forms, and the differences are not cosmetic. They set the tax base, the rate, the roll, the lien, and the appeal path.

The lessee-user tax. Minnesota and Michigan tax the private lessee of exempt property as though the lessee owned it. The measure is the property, not the bargain. Michigan's formulation is the clearest in the country: the lessee "is subject to taxation in the same amount and to the same extent as though the lessee or user owned the real property." Both states then publish a list of exceptions, and whether hangars appear on that list is the whole ballgame. In Minnesota they do. In Michigan they do not.

The possessory interest. California and Colorado assess the tenant's private right to possess public property as a distinct taxable object. Both build value from the lease, but in opposite directions. California excludes the rent obligation from the base and requires that the present value of unpaid contract rent be added back to a sale price before that sale can be used as evidence of value. Colorado does the reverse, constructing the base out of the rent stream the tenant pays the government.

The improvement account. Texas, Colorado, and North Carolina reach the physical hangar directly, as real property listed to whoever owns it, with the land carried separately and exempt. North Carolina is the pure case: the leasehold is statutorily invisible, but the building is not.

Exemption denial. Ohio and Florida never create a separate taxable object at all. Their public-property exemptions turn on use, so a private lease simply strips the exemption from the leased portion, which is then split off and taxed. Nothing new is invented; something existing is withdrawn.

An excise instead of a tax. Washington removed leasehold interests in public property from the property tax entirely and substituted a leasehold excise tax measured by contract rent. The burden follows the rent, not the value, which makes Washington the one state where a below-market ground lease reduces the bill rather than raising it.

Georgia belongs to none of these. It asks a prior question of property law: did the lease convey an estate at all, or only a right to use? If only the latter, there is nothing to tax and nothing to argue about.

The 15-state comparison

Read across a row and the same physical asset, an enclosed structure sheltering an aircraft on government land, is reached by five different legal theories, placed on different rolls, and measured against different benchmarks. That is why no national rule of thumb for hangar assessed value exists, and why any appraisal that reports a dollars-per-square-foot figure without first naming the taxable object is unreliable.

What federal law does and does not decide

Owners frequently assume that because a hangar is federally regulated, it is federally protected from local taxation. It is not. Federal airport law governs use and revenue. State law governs tax. The two run on separate tracks, and a hangar can be in perfect federal compliance and still generate a five-figure annual tax bill.

The current authority is FAA Order 5190.6C, Airport Compliance Manual, effective February 2026, which cancels and replaces Order 5190.6B. Anyone still citing 5190.6B is working from a superseded document. Three chapters bear on hangar leases: Chapter 12, review of aeronautical lease agreements; Chapter 15, permitted and prohibited uses of airport revenue; and Chapter 18, airport rates and charges, which requires rates to be fair and reasonable and the airport to maintain a self-sustaining rate structure.

The self-sustaining requirement is where tax and federal policy actually touch. A sponsor that agrees to absorb a tenant's property tax, or that sets ground rent below market to compensate a tenant for a tax burden, is making a revenue decision the FAA can review. That is a reason to negotiate the tax allocation clause explicitly rather than leaving it to be inferred.

The second federal document matters because of a single sentence about ownership. The FAA Policy on the Non-Aeronautical Use of Airport Hangars, 81 Fed. Reg. 38906 (June 15, 2016), effective July 1, 2017, states that it applies to all users of aircraft hangars "regardless of whether a user is an owner or lessee of the hangar," and that "when land designated for aeronautical use is made available for construction of hangars, the hangars built on the land are subject to the sponsor's obligations to use aeronautical facilities for aeronautical use."

Read that against the state law below and the asymmetry is stark. Building the hangar at your own expense on a ground lease buys you no relief from the federal use restrictions. In most of these states it also buys you no relief from tax; in several it is precisely what creates the tax, because a lessee-owned improvement is exactly the object the assessor lists. The policy also settles what counts as aeronautical use: storage of active aircraft, final assembly of aircraft under construction, non-commercial construction of amateur-built or kit-built aircraft, maintenance and repair, and storage of aircraft handling equipment, with non-aeronautical items permitted so long as they do not interfere with the aeronautical use.

Minnesota

Hangars exempt by nameTwo carve-outs

Minnesota has the strongest hangar-specific statutory hook in the country, and almost no one outside the state knows it exists.

The baseline is a conventional lessee-user tax. Under Minn. Stat. § 272.01 subd. 2(a), when tax-exempt property is leased, loaned, or otherwise made available and used by a private individual, association, or corporation in connection with a business conducted for profit, tax is imposed "in the same amount and to the same extent as though the lessee or user was the owner." Standing alone, that language would put every commercial hangar tenant in the state on the roll.

Subdivision 2(b) then lists exceptions, and clause (2) is written for hangars. The tax does not apply to property of an airport owned by a city, town, county, or group thereof which is:

(i) leased to or used by any person or entity including a fixed base operator; and (ii) used as a hangar for the storage or repair of aircraft or to provide aviation goods, services, or facilities to the airport or general public

Minn. Stat. § 272.01 subd. 2(b)(2)

Note how wide that is. It covers the fixed base operator explicitly. It covers repair as well as storage. It covers aviation goods and services generally, not merely aircraft shelter. A hangar tenant at a small Minnesota municipal or county airport is, by statute, outside the lessee-user tax.

The two carve-outs

The exception is then withdrawn in two situations, and both are easy to fall into.

First, by airport. The exception does not apply to property located at an airport owned or operated by the Metropolitan Airports Commission, or by a city of over 50,000 population according to the most recent federal census, or by such a city's airport authority. This is a geographic line, not a use line. Identical hangars, identical leases, identical operations: one is exempt because the sponsor is a small county, the other is taxable because the sponsor sits in the Metropolitan Airports Commission system or is a larger city. Population is measured by the most recent federal census, which means a city can cross the threshold and change the tax status of every hangar on its field without anyone at the airport doing anything.

Second, by use. The exception does not reach hangars leased by a private individual, association, or corporation in connection with a business conducted for profit other than an aviation-related business. Profit is not disqualifying; non-aviation profit is. A maintenance shop keeps the exemption. A contractor storing landscaping equipment in a hangar does not, and neither does the aviation tenant who quietly sublets half the floor to one.

Two adjacent clauses round out the airport treatment: subd. 2(b)(3) excepts public pedestrian ramps and concourses at public airports, and subd. 2(b)(4) excepts passenger check-in areas, ticket counters, boarding areas, and luggage claim areas, subject to the same large-airport carve-out. Minnesota, in other words, deliberately built an aviation architecture into its lessee-user tax and then deliberately excluded its largest airports from it.

Nevada

On-airport property exceptedOff-airport airport-owned land taxable

Nevada taxes leasehold and possessory interests in exempt real estate, then excepts public airports from that tax. The result is the second clean exemption in this survey, and it is broader than Minnesota's because it does not depend on the size of the sponsor.

NRS § 361.157(1) provides that when exempt real estate is leased, loaned, or otherwise made available to and used by a natural person, association, partnership, or corporation in connection with a business conducted for profit or as a residence, "the leasehold interest, possessory interest, beneficial interest or beneficial use of the lessee or user of the property is subject to taxation," to the extent the portion of the property and the percentage of time it is used can be segregated and identified.

Subsection 2 then lists fourteen exceptions, lettered (a) through (n). The first is the airport exception:

Property located upon a public airport, park, market or fairground, or any property owned by a public airport, unless the property owned by the public airport is not located upon the public airport and the property is leased, loaned or otherwise made available for purposes other than for the purposes of a public airport, including, without limitation, residential, commercial or industrial purposes;

NRS § 361.157(2)(a)

Parse the "unless" carefully, because it is the single most misread clause in Nevada aviation tax. The exception covers two categories: property located upon a public airport, and property owned by a public airport wherever it sits. The carve-back attaches only to the second category, and it requires two conditions together: the property is not located upon the airport, and it is made available for non-airport purposes.

So an on-airport commercial leasehold (hangar, FBO, maintenance facility, terminal concession) stays inside the exception and is not reached by § 361.157, regardless of how commercial it is. What falls out is the off-airport parcel that an airport authority owns as an investment and leases for a shopping center. That tenant is taxable; the hangar tenant on the field is not.

Two structural details are worth carrying into any Nevada engagement. Where the tax does apply, NRS § 361.157(3) provides that it "do[es] not become a lien against the property"; it is a debt from the lessee or user to the county, recoverable in court. And taxability turns on NRS § 361.2275, which asks whether the possession or claim is independent, durable, and exclusive of rights held by others. That is the same trio California uses, imported into a statute that then exempts airports anyway.

Texas

Narrow exception, sponsor-dependent

Texas starts from the proposition that a possessory interest in exempt property is listed and taxed. Tax Code § 25.07(a) provides that, except as provided by subsection (b), "a leasehold or other possessory interest in real property that is exempt from taxation to the owner of the estate or interest encumbered by the possessory interest shall be listed in the name of the owner of the possessory interest if the duration of the interest may be at least one year."

Subsection (b) then removes seven categories from that rule. The aviation category is (b)(3), and it has two independent conditions that must both be satisfied. The property must be "part of a public transportation facility owned by a municipality or county," and it must be one of four listed facility types. The two that matter for hangars are:

(A) is an airport passenger terminal building or a building used primarily for maintenance of aircraft or other aircraft services, for aircraft equipment storage, or for air cargo;
(B) is an airport fueling system facility;

Tex. Tax Code § 25.07(b)(3)

Subparagraphs (C) and (D) round out the list with foreign-trade zone property at certain joint-airport-board and two-county airports. They are unlikely to reach a general aviation hangar, but they are part of the provision and should not be overlooked when the facility sits in an FTZ.

The leasehold rule is also not the only route to a tax bill in Texas. Under § 25.04, when different persons own land and improvements in separate estates or interests, "each separately owned estate or interest shall be listed separately." Section 25.08 handles the mechanics: an improvement may be listed with the land, but where the improvement is held by someone other than the landowner, the parties may file a written request before May 1 for separate taxation, after which land and improvement are "listed separately in the name of the owner of each." A privately owned hangar on exempt airport land is therefore capable of appearing as its own improvement-only account regardless of how the leasehold question comes out.

Florida

Noncommercial hangars exemptFor-profit lessees taxable

Florida decides the question by exemption denial, and the operative test is the character of the lessee's activity.

Fla. Stat. § 196.199(2)(a) provides that leasehold interests in property of the United States, the state, its political subdivisions, municipalities, agencies, authorities, and other public bodies corporate "shall be exempt from ad valorem taxation and the intangible tax pursuant to paragraph (b) only when the lessee serves or performs a governmental, municipal, or public purpose or function, as defined in s. 196.012(6)." Where that test is met, the statute adds that "all other interests in the leased property shall also be exempt."

The most quotable hangar-specific administrative authority in the country then applies that test directly to hangars. Florida Attorney General Opinion 2019-06, "Ad valorem taxation, municipal aircraft hangar leases," dated August 16, 2019, addressed City-owned hangars at Fernandina Beach Municipal Airport leased to private aircraft owners for storage. The conclusion:

The leasehold interests owned by Fernandina Beach and leased to private aircraft owners are exempt from ad valorem taxation under section 196.199(2)(a) [provided] the lessees are using the leaseholds for a noncommercial aviation or airport purpose or operation with no engagement in for-profit activity.

Fla. AGO 2019-06 (Aug. 16, 2019)

The reasoning is worth understanding, because it is portable. The Attorney General treated the provision of hangar and tie-down space to individual aircraft owners as an activity that "could properly be performed or served by an appropriate governmental unit," which is what § 196.012(6) requires. The hangars were used solely for noncommercial storage of private aircraft and supported noncommercial aeronautical users.

The caveat is equally clear, and it is the operative risk. The exemption holds only where the lessee engages in no for-profit activity. A private owner storing a personal aircraft is on one side of that line; an FBO, a charter operator, a flight school, and a maintenance business are on the other. The line is drawn at the lessee's activity, not at the airport's character or the sponsor's intent.

Florida's structural oddity

Where a leasehold is taxable, § 196.199(2)(b) does something no other state in this survey does: it changes the kind of property the interest is. A taxable leasehold is taxed only as intangible personal property under chapter 199 if rental payments are due under the lease, and as real property if no rental payments are due. The classification therefore turns on whether rent is payable, which is a drafting fact, not an economic one. A nominal-rent hangar lease and a no-rent hangar lease can land in two different tax regimes.

We verified the bifurcation in the statute itself. We did not verify from a primary source what the chapter 199 branch produces as an actual bill under current Florida law, and this article does not assert a figure for it.

California

Taxable possessory interestCommon understanding is wrong

California does not exempt the private occupant of public land. It assesses a taxable possessory interest, and hangars are named as an example in the Board of Equalization's own plain-language guidance. The BOE fact sheet Taxable Possessory Interests defines the object as "a possession, a right to the possession, or a claim to a right of the possession of publicly owned real property that is independent, durable, and exclusive of rights held by others, and that provides a private benefit to the possessor," and lists among its examples "aircraft hangars and tie-downs at publicly owned airports."

That much is well understood. What follows is not.

Reason one: it reaches only certificated carriers. Section 107.9 creates "an additional taxable possessory interest conferred upon an operator of certificated aircraft at a publicly owned airport." The Assessors' Handbook glosses this as operators of certificated aircraft, "i.e., commercial airlines." A general aviation owner is not within the section's scope at all.

Reason two: hangars are expressly excluded. Even for a commercial airline, the statute carves hangar interests out of its own formula. The opening subdivision defines the "excluded possessory interests" as those:

stated in a written agreement for terminal, cargo, hangar, automobile parking lot, storage and maintenance facilities and other buildings and the land thereunder leased in whole or in part by an airline

Cal. Rev. & Tax. Code § 107.9(a)

Hangar facilities are named, third in the list. The section then confirms at (b)(5) that "[n]othing in this subdivision is intended to apply to the determination of a term of possession for a possessory interest in an excluded possessory interest."

Two further points of precision, since the formula is widely paraphrased loosely. First, § 107.9 is a safe harbor, not a mandate. The statute confers a presumption of correctness "only if the assessor uses the following direct income approach"; the Assessors' Handbook explains that if the prescribed method is not followed, "the assessment's usual presumption of correctness is lost." Second, the benchmark is one-half of the landing fee rate used to calculate the 1996-97 assessment, annually adjusted by the California Consumer Price Index and capped so that the adjusted rate never exceeds one-half of the airport's actual landing fee rate for the last full fiscal year. The twenty-year figure is the outer cap on the term under (b)(4); other sub-cases run ten to fifteen years and five to fifteen years. Section 107.9 was added by Stats. 1998, ch. 85, and has never been amended.

What actually governs a general aviation hangar

Ordinary possessory interest methodology. The Assessors' Handbook states that "[t]he valuation of taxable possessory interests is primarily addressed in Rule 21," and Rule 21 lists §§ 107 and 107.1 as its authority, not § 107.9. County assessor guidance matches: Madera County lists "T-hangars at airports" and "Hangar buildings at airports" as possessory interests citing § 107 and Rule 20 et seq., with no mention of § 107.9.

Two Rule 21 mechanics drive value. The term of possession for valuation purposes is the reasonably anticipated term, with the stated term presumed correct unless a different mutual understanding is shown by clear and convincing evidence. And for post-De Luz interests, the direct comparison method requires adding to the sale price "the present value on the sale date of any unpaid future contract rent for the term of possession." That add-back is the reason enrolled possessory interest values in California systematically exceed observed leasehold hangar sale prices. An appraiser who compares an enrolled value to a leasehold transfer price without making it is comparing two different things.

The misconception is documented in official-adjacent material: Santa Clara County's Airports Division page on possessory interest tax, addressed to hangar and tie-down permittees, cites both § 107 and § 107.9. That page is not the Assessor's and expressly disclaims control over the tax, but it is fair evidence of how widely the assumption travels.

Washington

Not a property tax at all

Washington removed leasehold interests in public property from the property tax and replaced them with an excise. This is a different tax on a different base, and treating it as a property tax produces wrong numbers in both directions.

The leasehold excise tax under RCW ch. 82.29A is, in the Department of Revenue's words, "a tax on the use of public property by private party. This tax is in lieu of the property tax." The rate is 12.84 percent of contract rent. The Department of Revenue states the rate as .1284 and reports that roughly 53 percent goes to the State General Fund with 47 percent returned to the county and city where the property sits. The underlying split of 6.84 percent state and 6.00 percent local comes from the statute rather than the rate page: RCW 82.29A.030(1) levies 12 percent with a credit for the local tax, RCW 82.29A.030(2) adds the surtax set at 7 percent by RCW 82.02.030, and RCW 82.29A.040 authorizes counties up to 6 percent, with city tax credited against the county's. The Department retains 2 percent of the county and city receipts for administration.

The history explains the structure. The Washington Supreme Court held in Pier 67 v. King County (1970) that a leasehold interest in publicly owned property could be taxed; the legislature responded in 1976 with the excise, initially at 12 percent, resolving longstanding complaints about unequal treatment of leasehold and fee interests in public property.

The definition is deliberately broad

WAC 458-29A-100 defines a leasehold interest as an interest granting the right to possession and use of publicly owned property "as a result of any form of agreement, written or oral, without regard to whether the agreement is labeled a lease, license, or permit." The rule adds that "both possession and use are required to create a leasehold interest, and the lessee must have some identifiable dominion and control over a defined area to satisfy the possession element."

For hangar practice this cuts two ways. Calling the document a permit rather than a lease does not avoid the tax. But a genuinely non-exclusive arrangement, shared ramp access with no defined area under the tenant's dominion and control, may fail the possession element. The line is dominion and control over a defined area, not the label on the paper.

Scale

The tax is not a rounding error. Washington DOR's Table 20 reports local leasehold excise tax distributions of $30,944,993 in FY2020, $32,150,913 in FY2021, and $35,098,348 in FY2022: $15,700,092 to counties and $19,398,256 to cities. King County alone received $16,283,007 in FY2022, roughly 46 percent of the statewide total, with Pierce ($3,402,953) and Snohomish ($3,080,969) next. Note that these are distributions to local government, a different series from state collections, which the Tax Reference Manual reports at $36,281,000 in FY2019, $36,205,000 in FY2020, and $37,206,000 in FY2021. The two figures are frequently conflated; they should not be.

Arizona

Ordinary ad valoremOnly state with a hangar use code

Arizona is the state most often misdescribed in national summaries, usually by assuming that the Government Property Lease Excise Tax swallows airport hangars. The evidence points the other way.

GPLET, A.R.S. §§ 42-6201 through 42-6210, imposes a per-square-foot excise on government property improvements leased to private parties. The rate schedule, posted by the Department of Revenue under A.R.S. § 42-6203(B), contains no aviation, airport, hangar, or aircraft category. For tax year 2026 the rates are: one-story office $3.37; two to seven story office $3.87; eight or more story office $5.22; retail $4.23; hotel/motel $3.37; warehouse/industrial $2.27; residential rental $1.28; all others $3.37; and parking $336.80 per space. A hangar reaching GPLET at all would fall to warehouse/industrial or to all others. Note that leases predating June 1, 2010, and leases entered within ten years under a pre-2010 development agreement, ordinance, or resolution, are subject to a different rate schedule.

Whether any hangar actually does is a separate question, and here the absence is the finding. Arizona maintains no central statewide GPLET database. The Department of Revenue publishes only links to individual government lessors, county by county. That list currently runs to 41 government lessors (cities, towns, and two counties), and not one airport, airport authority, aviation department, or air-related entity appears on it. For a state with the general aviation activity Arizona has, that is a meaningful negative result: GPLET does not appear to be the operative regime for hangars.

The hangar use codes

What Arizona does have is unique. It is the only state in this survey with purpose-built hangar categories in its property classification system. The Department of Revenue's Property Use Code Manual carries:

• 22-6  Aircraft Hangar Condominium: a development in which individual units are parceled with fractional, undivided interests in the land
• 22-4  Improved Private Air Field: noted as possibly including aircraft hangars
• 22-5  Unimproved Private Air Field
• 15-8  Office Building with aircraft hangar
• 37-8  Office/Retail Warehouse with an aircraft hangar

A dedicated code for a hangar condominium tells you what the Arizona market looks like and how the assessor expects to encounter it: as a deeded or leasehold condominium parcel on the ordinary roll, valued and classified like other real property, not as an excise account. The manual itself does not map use codes to legal classes or assessment ratios, so the applicable class and ratio must be confirmed against the assessment statutes and the county assessor's records for the specific parcel.

The conclusion that Arizona hangars are reached as ordinary taxable property rather than through GPLET is an inference from the rate schedule, the lessor database, and the use code manual. It is well supported by those three official sources but is not a statement any one of them makes expressly.

Michigan

Taxed as though you owned itNo hangar exception

Michigan is Minnesota's mirror image. Same tax, same structure, same list of exceptions, and hangars are not on the list.

The lessee-user tax, MCL § 211.181 (Act 189 of 1953), provides:

Except as provided in this section, if real property exempt for any reason from ad valorem property taxation is leased, loaned, or otherwise made available to and used by a private individual, association, or corporation in connection with a business conducted for profit, the lessee or user of the real property is subject to taxation in the same amount and to the same extent as though the lessee or user owned the real property.

MCL § 211.181(1)

"In the same amount and to the same extent as though the lessee or user owned the real property" is the harshest formulation in this survey. There is no leasehold-advantage measure, no capitalization of a rent bargain, no discount for the finite term. The tenant is taxed on the property as an owner would be.

Subsection (2) lists the exceptions. The airport entry is a concession provision:

Property that is used as a concession at a public airport, park, market, or similar property and that is available for use by the general public.

MCL § 211.181(2)(b)

Concessions at public airports are excepted. Hangars are not. And the Michigan Tax Tribunal has applied exactly that distinction to an aviation tenant. In a case involving Beacon Aviation, the Tribunal held the petitioners subject to the lessee-user tax because they failed to establish that the operation qualified as a concession under (2)(b), emphasizing that both conditions must be satisfied: use as a concession and availability to the general public. An aviation business at a public airport had to argue its way into the concession exception because there was no aviation exception to argue.

Practical consequence: a Michigan hangar tenant operating any for-profit business should budget for an ad valorem bill computed as though it held fee title, and should read the ground lease's tax clause before assuming the sponsor absorbs it.

A note on sourcing. The Michigan Legislature's website was not machine-retrievable during this research. The statutory language quoted above is taken verbatim from published opinions of the Michigan Tax Tribunal, an official state tribunal, which reproduce it. We did not obtain the complete list of subsection (2) exceptions from the code itself; the conclusion that no aviation or hangar exception exists rests on the statutory text we did read and on the Tribunal's own analysis, which treated the concession provision as the applicable airport exception.

Alaska

Taxable to the extent of the interestMunicipal only

Alaska taxes the private interest, but the first question is whether anyone is levying a tax at all.

Property taxation in Alaska is municipal. There is no statewide general property tax on hangars, and large parts of the state are not inside a taxing municipality. Where a borough or city does levy, AS § 29.45.030(a)(1) requires exemption of government property but preserves the taxability of a private interest in it. Alaska's Division of Community and Regional Affairs states the rule plainly:

Article IX, Section 5 of the State Constitution and AS 29.45.030 state that these private uses are taxable, with certain exceptions, and "to the extent of that interest." … An example of taxable property would be a lease on public land to an individual or entity. This leasehold interest would be taxable regardless of the amount of the lease payment.

Alaska Div. of Community & Regional Affairs, Property Tax Exemptions in Alaska

That last clause matters more than it looks. "Regardless of the amount of the lease payment" signals that Alaska does not follow the leasehold-advantage measure used in Tennessee and pre-2019 North Carolina, where a market-rent lease produces little taxable value. A hangar tenant paying full market ground rent in a taxing Alaska borough should not expect the rent level to defeat the assessment.

Because administration is entirely local, the practical answer for any specific Alaska hangar comes from the borough or city assessor. Two hangars 200 miles apart can face wholly different regimes, one inside an organized borough that levies, one in an area that does not.

We were unable to retrieve the verbatim text of AS § 29.45.030(a)(1) from the Alaska Legislature's own site. The statement of the rule above is quoted from a State of Alaska executive agency publication rather than from the statute directly.

Colorado

Two taxable objectsAviation exemption expressly denied to tenants

Colorado is the most expensive state in this survey to misread, because a hangar on leased public airport land generates two taxable items, not one.

Item one: the improvement. C.R.S. § 39-1-102(6.3) defines improvements as "all structures, buildings, fixtures, fences, and water rights erected upon or affixed to land, whether or not title to such land has been acquired." The hangar is taxable real property in its own right, classified by use, without regard to who owns the dirt. The Division of Property Taxation's Assessors' Reference Library says so using hangars as its example, noting that where a privately owned building is erected on exempt land, "airplane hangars at a public airport," the building is classified as real property and conveyed by deed.

Item two: the possessory interest in the ground lease. C.R.S. § 39-1-103(17) governs, and Colorado's valuation rule is the inverse of California's:

the actual value of the possessory interest shall be determined by the present value of the reasonably estimated future annual rents or fees required to be paid by the holder of the possessory interest to the owner of the underlying real or personal property through the stated initial term of the lease

C.R.S. § 39-1-103(17)(a)(II)(A)

Read that twice. Colorado capitalizes the rent obligation itself (what the tenant pays the government), not the bargain element, not the excess of market over contract rent. The statute directs use of actual contract rents unless they are shown not to be representative of market, in which case market rents are substituted. The Colorado Supreme Court applied the formula to Denver International Airport concessionaires in Cantina Grill, JV v. City & County of Denver Board of Equalization, 2015 CO 15, affirming use of a lease's minimum monthly guarantee as the reasonably estimated future rents. "Initial term" excludes options to renew until they are exercised. Rents attributable to non-exclusive rights (roads, rights-of-way, easements, common areas) must be stripped out under (17)(a)(II)(B).

The Assessors' Reference Library, which is binding on county assessors, assigns airport possessory interests their own abstract subclass, code 2020, described as covering possessory interests in government-owned, tax-exempt airport land and improvements, with lessee-owned improvements classified according to use and assigned to the corresponding subclass. Colorado is the only state in this survey that has built the airport hangar case directly into its assessment coding.

Two administrative points. Under C.R.S. § 39-1-107(4) the possessory interest tax "shall not become a lien against the property"; it is a debt due from the holder to the board of county commissioners. And the nonresidential assessment rate is mid-transition: C.R.S. § 39-1-104(1.9) sets 27 percent for tax year 2025, 26 percent for 2026 with 25 percent for improved commercial subclass codes and agricultural property, and 25 percent for 2027 and after. Confirm the rate for the applicable year rather than carrying a figure forward.

Georgia

Usufruct not taxableEstate for years taxable

Georgia asks a question no other state in this survey asks, and the answer disposes of the tax entirely. The question is not how to value the tenant's interest. It is whether the lease conveyed an interest in real property at all.

Georgia law distinguishes a usufruct, a mere right to possess and enjoy the use of real estate, from an estate for years, which is an interest in real property. The Supreme Court of Georgia stated the consequence in Clayton County Board of Tax Assessors v. Aldeasa Atlanta Joint Venture, 304 Ga. 15 (2018), a Hartsfield-Jackson case:

Because a usufruct is not considered an estate in real property under Georgia law, it is not subject to ad valorem property tax.

Aldeasa, 304 Ga. 15 (2018)

And in a holding that matters enormously for hangars, the Court extended it to the improvements:

The improvements that Clayton County attempts to tax are fixtures to realty. … The trial court properly concluded, however, that Aldeasa held only a usufruct and not an estate in real property. It follows that Aldeasa could not be assessed for leasehold improvements that were not personal property but instead were attached to and passed with the real property it did not own.

Aldeasa, 304 Ga. 15 (2018)

If the ground lease conveys a usufruct, then neither the tenant's interest nor the hangar it built is taxable to the tenant. This is the single most valuable holding for a Georgia hangar owner in this entire article.

Which one did your lease convey?

Term length creates only a rebuttable presumption. The Court of Appeals in City of College Park v. Paradies-Atlanta, LLC, 346 Ga. App. 63 (2018), stated that where a lease term exceeds five years a rebuttable presumption of an estate for years arises, and then set out the factors that rebut it: the terms used to describe the grantee's rights; provisions addressing liability for ad valorem taxes; the grantor's retention of dominion or control over the leased property; which party maintains the premises; and whether the grantee may assign or allow others to use the premises without consent.

Long terms routinely still produce usufructs. Georgia courts have found usufructs in thirty-year airline leases, a thirty-five year lease, and fifty-year leases, where the sponsor retained pervasive control. Critically, the label in the document does not decide it. Aldeasa held that in a tax dispute "the provisions of the agreement must be objectively scrutinized to determine the legal effect of the agreement, despite its terms stating it creates a usufruct." An airport ground lease with sponsor rights to terminate, relocate, or control operations is a strong usufruct candidate however it is captioned.

Georgia does have one aviation-specific taxing provision, and it is narrow. O.C.G.A. § 6-3-21 addresses municipal airport land lying outside the sponsoring political subdivision's territorial limits, and declares that private interests there are subject to ad valorem taxation, but only, since a 2014 amendment, "so long as the interests create an estate in land." It does not convert a usufruct into a taxable interest. Separately, O.C.G.A. § 48-5-15.1 is a situs rule allocating the taxing county at airports divided by county lines, expressly inapplicable to airports certificated under 14 C.F.R. Part 139.

Georgia's Appraisal Procedures Manual, DOR Rule 560-11-10, does not use the words "usufruct" or "estate for years" anywhere, and contains no guidance on improvements on exempt land. The doctrine lives in the case law and in Title 44, not in the assessment manual. We were unable to retrieve the official codified text of O.C.G.A. § 44-7-1 directly; its operative language is quoted here as reproduced verbatim within the appellate opinions cited.

Illinois

Taxable leasehold estateFBO exemption held unconstitutional

Illinois taxes the leasehold, the airport authority exemption does not protect the tenant, and the one legislative attempt to fix that for FBOs was struck down.

The governing provision is 35 ILCS 200/9-195:

when property which is exempt from taxation is leased to another whose property is not exempt, and the leasing of which does not make the property taxable, the leasehold estate and the appurtenances shall be listed as the property of the lessee thereof, or his or her assignee. … the lessee shall be liable for those taxes. However, no tax lien shall attach to the exempt real estate.

35 ILCS 200/9-195(a)

Section 9-195 opens with a closed list of cross-referenced exceptions: sections 15-35, 15-55, 15-60, 15-100, 15-103, and 15-185. Section 15-160, the airport authority exemption, is not among them. That omission is the whole Illinois answer.

Section 15-160 exempts property belonging to an airport authority and used for authority purposes "or leased to another entity, which property use would be exempt from taxation under this Code if it were owned by the lessee entity." The condition is doing the work: the lease preserves the exemption only where the lessee's own use would independently qualify. A for-profit hangar tenant or FBO does not qualify. Similarly, 35 ILCS 200/15-60(c) keeps municipal property exempt when leased but routes "the leasehold interest of the lessee" to assessment under section 9-195.

The Illinois Supreme Court confirmed the practical result in Moline School District No. 40 Board of Education v. Quinn, 2016 IL 119704, which struck down Public Act 97-1161, a statute exempting leasehold interests and improvements of a fixed base operator at the Metropolitan Airport Authority of Rock Island County, as special legislation under the Illinois Constitution. The opinion also records the baseline: "Illinois has assessed property taxes on airport property leased to FBOs, and Elliott Aviation has been required to pay property tax on the FBO it operates at the Quad City airport in Moline."

Valuation follows leasehold logic. In United Airlines, Inc. v. Pappas, an O'Hare leasehold case, the appellate court described the fair cash value of a leasehold as "the rental value in the market — the amount a willing lessee will pay a willing lessor, in a voluntary transaction, for the right to use and occupy the premises," and held that where comparable airport leases exist, failing to consider the sales comparison approach is fatal to a taxpayer's case.

The one genuine relief available

Not an exemption, but a valuation preference. In counties of 200,000 or more inhabitants, 35 ILCS 200/10-90 allows property used for airport purposes for the three preceding years to be valued "on the basis of 33 1/3% of its fair cash value, based upon the price it would bring at a fair, voluntary sale for use by the buyer for airport purposes." It requires an annual application to the chief county assessment officer by January 1 under section 10-95, and it carries a recapture: when the land ceases to be used for airport purposes, the difference in taxes for each of the three preceding years becomes payable with 5 percent interest under section 10-100. The statute keys the benefit to "the person liable for the taxes," which under 9-195 is the lessee, though we found no primary authority expressly confirming that a leasehold interest may claim it.

Exemption claims in Illinois are decided by the Department of Revenue, not finally by the board of review, and under 86 Ill. Adm. Code 110.115 an application for exemption of a leasehold estate must be filed by the lessee.

North Carolina

Leasehold excluded since 2019Building still taxable

North Carolina made a clean statutory change in 2018 that practitioners still miss, and it produces the most surgical split in this survey: the leasehold is invisible, the building is not.

The mechanism is classification, not exemption. N.C.G.S. § 105-273(8) defines intangible personal property to include "leasehold interests in exempted real property." N.C.G.S. § 105-275(31) then excludes intangible personal property from the tax base. A leasehold interest in exempt airport land is therefore excluded from taxation, with no application required.

This is recent. Before Session Law 2018-98, § 105-275(31) carved leaseholds in exempt real property out of the intangibles exclusion, making them taxable to the lessee. The 2018 act, titled in part "to conform treatment of leasehold interests in exempt property to that of other types of intangible personal property," removed the carve-out effective for taxes imposed for taxable years beginning on or after July 1, 2019. Any analysis, memorandum, or assessor training material predating that change states the opposite rule and should not be relied on.

Where the ground lease vests title to improvements in the airport authority, on completion or on reversion, the hangar becomes government-owned and the ownership-based exemption of § 105-278.1(b) applies. North Carolina's exemption turns purely on ownership, without a use requirement: "Real and personal property belonging to the State, counties, and municipalities is exempt from taxation." The statute expressly names airport authorities among the units of local government whose property qualifies. In North Carolina, therefore, the title-to-improvements clause in the ground lease is the tax clause, whether or not it says so.

The ownership rule is judicial as well as statutory, and the leading case is an airport case. In In re Appeal of the University of North Carolina, 300 N.C. 563 (1980), the disputed parcels included the portion of an airport leased to a private airplane maintenance and repair firm together with storage space rented to individual airplane owners. The Supreme Court held that "State owned property is exempt from ad valorem taxation solely by reason of State ownership, regardless of the property's use," striking the then-existing public-purpose requirement as unconstitutional.

One further provision may matter to a very small number of owners. N.C.G.S. § 105-275(50) excludes 50 percent of the appraised value of real and personal property located at a "qualifying airport" and customarily used for aviation purposes. The qualifying criteria are demanding: designation as a legacy airport by NCDOT under G.S. § 63-59, general aviation airport status, location within a municipality's corporate limits, and economic output of $850 million or more per a January 2023 study. The exclusion is owner-agnostic, so it reaches privately owned hangars where it applies. We were not able to confirm from a primary source which airport or airports currently qualify.

Ohio

Exemption denial and split listingHangar case law directly on point

Ohio's public property exemption is a use exemption, and that single design choice decides the hangar question.

Real or personal property belonging to the state or United States used exclusively for a public purpose, and public property used exclusively for a public purpose, shall be exempt from taxation.

Ohio R.C. § 5709.08(A)(1)

Government ownership is necessary but not sufficient. Lease a portion of a public airport to a private party and that portion stops being public property used exclusively for a public purpose. The Supreme Court of Ohio described the rule and its aviation origin in O'Keeffe v. McClain, 2021-Ohio-2186:

Under R.C. 5709.08, if a portion of a public airport is leased to private persons, that portion "loses its identity as public property used exclusively for a public purpose and is not exempt from taxation." Carney v. Cleveland … In Carney, this court refused exemption to hangars leased to private companies under long-term leases.

O'Keeffe v. McClain, 2021-Ohio-2186, ¶ 46

Ohio then reaches the hangar without inventing a leasehold tax. The hangar is real property (R.C. § 5701.02 defines a building to include a shelter for tangible personal property with structural integrity independent of what it shelters), and R.C. § 5713.04 requires split listing where part of a parcel would be exempt and part would not: the exempt part is listed exempt, and "the balance thereof used for a purpose not exempt shall, with the approaches thereto, be listed at its taxable value and taxed accordingly."

Ohio's one statute that deems leased public land to be the lessee's own property, R.C. § 5709.06, reaches lands held "under a lease for a term of years renewable forever and not subject to revaluation." An ordinary twenty- or thirty-year hangar ground lease is not perpetually renewable and falls outside that rule. (The section also reaches congressional school and ministerial lands held under a perpetual lease subject to revaluation, which is a different category and not an airport situation.)

Two traps specific to Ohio

Port authority airports. Several Ohio commercial airports are operated by port authorities. R.C. §§ 4582.20 and 4582.46 exempt port authority property used exclusively for an authorized purpose, and then switch the exemption off expressly: "This exemption shall not apply to any property occupied and used during a tax year by a person who is a lessee of the property as of the tax lien date for that tax year under a written lease with a remaining term longer than one year." A hangar lease with more than a year to run defeats the port authority's own exemption for that property.

Do not over-read O'Keeffe. The taxpayer won in that case, but on a ground unavailable to almost any airport. The Ohio State University Airport was exempted under R.C. § 3345.17, the state-university property statute, which the Court noted "contains no exclusive-use limitation." A municipality, a regional airport authority, and a port authority have no equivalent. Under R.C. § 5709.08 the Carney rule governs and the leased hangar portion is taxable.

A related distinction is worth preserving: hiring a for-profit manager to run day-to-day operations is not the same as leasing. The Supreme Court held in RiverSouth Authority v. Harris, 2026-Ohio-2396, that engaging a for-profit manager does not defeat a political subdivision's direction and control. An FBO management agreement and a hangar lease are not interchangeable for exemption purposes.

Procedurally, R.C. § 5715.27 permits a lessee for an initial term of not less than thirty years to file the exemption application in its own name; the Tax Commissioner or county auditor determines taxability; appeal runs to the Board of Tax Appeals within sixty days and then to the Supreme Court or the court of appeals within thirty days.

Tennessee

Leasehold plus improvementsMeasured by the rent bargain

Tennessee has an explicit statutory provision on lessees of exempt property, and a valuation rule that makes the ground rent number the single most important fact in the file.

T.C.A. § 67-5-502(d) makes the lessee's interest separately assessable where the fee owner is exempt and the lessee is not. The Comptroller's Division of Property Assessments states the three conditions in its Appeals Handbook: the fee owner is exempt; the lessee is not exempt; and contract rent, including imputed rent, is less than market rent. "Typically," the handbook adds, "a leasehold assessment is basically made by calculating the present worth of the lessee's savings for the remaining term of the lease."

That the improvements ride along with the interest is confirmed on the face of the enacted law. Public Chapter 265 of 2019 amended § 67-5-502(d) with language expressly reaching "the lessee's or a sublessee's interest in any such real property, including any improvements erected upon the land," unless that interest is the subject of a lawful payment-in-lieu-of-taxes agreement with a local government, in which case the property is assessed solely to the governmental entity.

Valuation runs under T.C.A. § 67-5-605 and two Tennessee Supreme Court decisions the Comptroller quotes as the measure. State v. Grosvenor (1924): "[t]he value of a leasehold is to be based on the difference between the rent paid and the value of the use of property." Metropolitan Government of Nashville v. Schatten Cypress Co. (1975): valuation of a leasehold for tax purposes "is normally accomplished by determining whether there is an excess in fair rental value over the rent reserved in the lease."

Commercial and industrial real property is assessed at 40 percent of value under Article II, section 28 of the Tennessee Constitution. Appeals run from the county board of equalization to the State Board of Equalization (administrative judge, then Assessment Appeals Commission, then discretionary review by the full Board) and then to chancery court, where review is de novo with no presumption of correctness attaching to the decisions below. A lessee legally obligated to pay the ad valorem taxes has standing to appeal in its own right under T.C.A. § 67-5-1412(f).

There is no aviation exception reaching hangars. The one airport provision in the exemption title, T.C.A. § 67-5-219, exempts runways and aprons belonging to privately owned public-use airports, which is a different situation entirely. Yet Tennessee's leasehold doctrine was substantially built on airport disputes: three of the five leading leasehold-assessment authorities the Comptroller directs assessors to are aviation matters, involving a Memphis airport hotel, a Nashville flying service, and Federal Express at Memphis.

We were unable to retrieve the codified text of T.C.A. § 67-5-203, the government property exemption, from an official Tennessee source, and we therefore make no claim about whether it contains an airport-authority provision. Whether any tax exemption in Title 42 reaches airport lessees is likewise not established here.

What to check before you sign

The recurring failure in hangar transactions is not misvaluing the asset. It is failing to identify which object the assessor will reach, and therefore mispricing a recurring annual cost across a twenty- or thirty-year term. Six checks, in order.

1. Name the taxable object before you value anything. Improvement, possessory interest, leasehold estate, excise base, or nothing. A dollars-per-square-foot conclusion that does not first answer this question is not reliable, because leasehold and fee comparables trade on different bases and cannot be compared without adjustment.
2. Read the title-to-improvements and reversion clauses first. In North Carolina they decide taxability outright. In Colorado they decide whether you own a taxable improvement in addition to a possessory interest. In Georgia they feed the usufruct analysis. This is usually one paragraph, and it is usually the most consequential paragraph in the lease.
3. Confirm the sponsor's legal form, not just its name. Texas's exception runs only to municipalities and counties. Minnesota's turns on the Metropolitan Airports Commission and on city population. Ohio treats port authority airports differently from other public sponsors. Illinois treats airport authority property differently from municipal property. "Public airport" is not a tax category anywhere.
4. Model the ground rent as a tax input, not just a cost. In Washington the rent is the base, at 12.84 percent. In Colorado the rent stream is capitalized into the assessment. In Tennessee only the below-market portion is taxed. In California the rent is excluded from the base and added back to comparable sale prices. Four states, four opposite mathematical treatments of the same obligation.
5. Check the use restrictions on both tracks. Non-aviation commercial activity can independently violate the sponsor's federal obligations under 81 Fed. Reg. 38906 and destroy a state exemption under Minnesota's non-aviation-business carve-out or Florida's no-for-profit-activity condition. The tests are different and are enforced by different bodies.
6. Verify the account with the assessor in writing, for the specific parcel. Ask which roll it sits on, what the taxable object is, whether a lien can attach, and what the appeal deadline is. In several of these states the tax is a personal debt with no lien against the airport's land, which changes both the credit analysis and the remedy.

Limits of this survey

This article states what we were able to establish from primary sources as of August 2026. Where we could not, we say so rather than filling the gap, and the following are the material gaps.

• Michigan. The Legislature's website was not machine-retrievable. The statutory text is quoted from published Michigan Tax Tribunal opinions, and we did not obtain the complete list of exceptions in MCL § 211.181(2) from the code itself.
• Alaska. The verbatim text of AS § 29.45.030(a)(1) was not obtained from the Legislature's site; the rule is quoted from a State of Alaska agency publication.
• Tennessee. The codified text of T.C.A. § 67-5-203 was not retrievable from an official source, and no claim is made about airport-authority provisions within it or within Title 42.
• Washington. How a lessee-owned hangar improvement is separately assessed alongside the leasehold excise tax is not established here, and the common claim that improvements are carved out of the excise and routed to property tax is not supported by WAC 458-29A-100.
• Texas. Whether a private storage hangar qualifies as a building used for "aircraft equipment storage" under § 25.07(b)(3)(A) is an open interpretive question on which we located no controlling authority.
• Arizona. The conclusion that hangars are reached as ordinary property rather than through GPLET is an inference from three official sources, not an express statement in any of them.
• Florida. The practical effect of the chapter 199 branch of § 196.199(2)(b) under current law was not verified.
• Georgia and North Carolina. Certain older appellate opinions and one code section are quoted as reproduced within official sources we did read, rather than from the reporters directly. Which North Carolina airport qualifies under § 105-275(50) was not confirmed.

Rates and assessment ratios change. Colorado's nonresidential rate is mid-transition, Arizona's GPLET rates are set annually, and Washington's collections figures are reported on a fiscal-year lag. Confirm any figure for the applicable year before relying on it in a report or an appeal.

Finally, a general caution. This survey classifies architectures; it does not adjudicate parcels. Where a specific hangar's treatment is material to a transaction, an appeal, or an opinion of value, the answer comes from reading the actual ground lease and making a direct written inquiry to the assessor or property appraiser of record. The framework here will tell you which questions to ask and which answers should surprise you.

Authorities

Every source below was retrieved and read in preparing this article. Sources described in the text as quoted within other sources are identified as such above.

Statutes and constitutional provisions

• Minn. Stat. § 272.01 subd. 2: revisor.mn.gov
• Nev. Rev. Stat. §§ 361.157, 361.227(3), 361.2275: leg.state.nv.us; Nev. Admin. Code ch. 361: leg.state.nv.us
• Tex. Tax Code §§ 25.04, 25.07, 25.08: statutes.capitol.texas.gov
• Fla. Stat. § 196.199: leg.state.fl.us
• Cal. Rev. & Tax. Code §§ 107, 107.9 (Stats. 1998, ch. 85): reproduced at BOE Assessors' Handbook 510, App. A
• Rev. Code Wash. ch. 82.29A, esp. §§ 82.29A.030, 82.29A.040; RCW § 82.02.030; Wash. Admin. Code 458-29A-100: app.leg.wa.gov
• Ariz. Rev. Stat. §§ 42-6201 to 42-6210, § 42-6203(B)
• Mich. Comp. Laws § 211.181 (Act 189 of 1953)
• Alaska Stat. § 29.45.030(a)(1); Alaska Const. art. IX, § 5
• Colo. Rev. Stat. §§ 39-1-102(6.3), 39-1-103(17), 39-1-104(1.9), 39-1-107(4), 39-3-105, 41-3-107(1)(c) (HB 23-1156)
• O.C.G.A. §§ 6-3-21, 44-6-103, 44-7-1, 48-5-3, 48-5-15.1, 48-5-41
• 35 ILCS 200/9-195, 10-90, 10-95, 10-100, 15-55, 15-60, 15-160; 86 Ill. Adm. Code 110.115: ilga.gov
• N.C.G.S. §§ 105-273, 105-275, 105-276, 105-278.1, 105-282.1, 105-290, 105-302, 105-309, 105-345, 63-59; S.L. 2018-98: ncleg.gov
• Ohio Rev. Code §§ 5701.02, 5709.06, 5709.08, 5713.04, 5715.27, 5717.02, 5717.04, 4582.20, 4582.46: codes.ohio.gov
• Tenn. Code Ann. §§ 67-5-219, 67-5-502(d), 67-5-605, 67-5-801, 67-5-1412(f); Pub. Ch. 265 (2019): publications.tnsosfiles.com; Tenn. Const. art. II, § 28

Administrative and departmental guidance

• Fla. Att'y Gen. Op. 2019-06, Ad valorem taxation, municipal aircraft hangar leases (Aug. 16, 2019): myfloridalegal.com
• Cal. State Bd. of Equalization, Assessors' Handbook Section 510, Assessment of Taxable Possessory Interests (Dec. 2002, reprinted Jan. 2015): boe.ca.gov
• Cal. State Bd. of Equalization, Taxable Possessory Interests fact sheet: boe.ca.gov; Property Tax Rule 21: boe.ca.gov; Property Tax Annotation 660.0015
• Wash. Dep't of Revenue, Leasehold Excise Tax: dor.wa.gov; Tax Reference Manual ch. 17: dor.wa.gov; Table 20, Local Leasehold Excise Tax Distributions FY2020-2022: dor.wa.gov
• Ariz. Dep't of Revenue, GPLET Rate Information (TY2026): azdor.gov; Lessor Database: azdor.gov; Property Use Code Manual: azdor.gov
• Alaska Div. of Community & Regional Affairs, Property Tax Exemptions in Alaska: commerce.alaska.gov
• Colo. Div. of Property Taxation, Assessors' Reference Library vols. 2-3: arl.colorado.gov
• Ga. Dep't of Revenue Rule 560-11-10, Appraisal Procedures Manual: rules.sos.ga.gov
• Ill. Dep't of Revenue, PTAX-1004, The Illinois Property Tax System
• Tenn. Comptroller, Div. of Property Assessments, Appeals Handbook for Assessors of Property (Oct. 2023): comptroller.tn.gov; State Bd. of Equalization, Property Tax Exemption Manual (2023)

Cases

• Cantina Grill, JV v. City & County of Denver Bd. of Equalization, 2015 CO 15 (Colo. 2015)
• Clayton County Bd. of Tax Assessors v. Aldeasa Atlanta Joint Venture, 304 Ga. 15 (2018)
• City of College Park v. Paradies-Atlanta, LLC, 346 Ga. App. 63 (2018)
• Moline Sch. Dist. No. 40 Bd. of Educ. v. Quinn, 2016 IL 119704 (Ill. 2016)
• United Airlines, Inc. v. Pappas, Nos. 1-02-0687, 1-02-0771 (Ill. App. Ct. 1st Dist. 2004)
• In re Appeal of the University of North Carolina, 300 N.C. 563 (1980)
• O'Keeffe v. McClain, 2021-Ohio-2186 (Ohio 2021); RiverSouth Auth. v. Harris, 2026-Ohio-2396 (Ohio 2026)
• Carney v. Cleveland, 173 Ohio St. 56 (1962), as quoted in O'Keeffe
• Michigan Tax Tribunal, Docket No. 15-006901 (lessee-user tax; aviation lessee; concession exception)
• State v. Grosvenor (Tenn. 1924); Metro. Gov't of Nashville v. Schatten Cypress Co. (Tenn. 1975), as quoted by the Tennessee Comptroller

Federal

• FAA Order 5190.6C, Airport Compliance Manual (Feb. 2026), chs. 12, 15, 18: faa.gov
• FAA, Policy on the Non-Aeronautical Use of Airport Hangars, 81 Fed. Reg. 38906 (June 15, 2016), eff. July 1, 2017: federalregister.gov