PER CURIAM.
Marriott International Resorts, L.P. and Marriott International JBS Corporation (collectively, "Marriott") appeal the decision of the United States Court of Federal Claims in Marriott International Resorts, L.P. v. United States, 83 Fed.Cl. 291 (2008). The court determined that in 1994 the obligation to close a short sale qualified as a liability under I.R.C. § 752 and that the IRS properly adjusted the outside basis of the Marriott partners...
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