BRYAN, Judge.
Sustainable Forests, LLC ("the taxpayer"), appeals from a summary judgment entered in favor of the Alabama Department of Revenue ("the Department"). We affirm.
The taxpayer solely owns three single-member limited-liability companies, Red Mountain TimberCo I LLC, Red Mountain TimberCo IV LLC, and GMO Threshold Timber Courtland LLC (collectively, "the LLCs"). In October 2006, the taxpayer executed statutory warranty deeds conveying various tracts...
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