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In 1970, Congress imposed an annual registration tax on all civil aircraft that fly in the navigable airspace of the United States. The state of Massachusetts owned and utilized a helicopter for the purpose of patrolling highways and fulfilling other police duties. When Massachusetts refused to pay the tax, the federal government collected it from the state's accounts, plus interest and penalties. Massachusetts then sought a refund of the money collected.

Did the tax on civil aircraft violate the implied immunity of state governments from federal taxation?

No. The Court held that so long as charges did not discriminate against state functions, were based on fair approximations of uses of the system of navigable airspace, and were structured to produce revenues that did not exceed the total cost of the benefits to be supplied to national airsystem, there could be no basis for claims that the National Government was "using its taxing powers to control, unduly interfere with, or destroy" Massachusetts' ability to perform "essential services." The Court emphasized its reluctance to enlarge the scope of state immunity from federal taxation.