OPINION
GERBER, Judge.
The Marriott Corporation and its successor Marriott Management Services Corporation (collectively Marriott) appeal from the tax court's ruling that Marriott was not entitled to a refund of restaurant transaction privilege taxes. Marriott claims that the payments it received from the Theodore Roosevelt Council of the Boy Scouts of America (Council) were tax deductible because providing, preparing, and serving food to the Council's camps...
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