BRC OPERATING COMPANY LLC v. COMMISSIONER OF INTERNAL REVENUE

Docket Nos. 12922-16, 12923-16.

T.C. Memo. 2021-59

BRC OPERATING COMPANY LLC, BLUESCAPE RESOURCE COMPANY LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. BLUESCAPE RESOURCES COMPANY LLC, BLUESCAPE RESOURCES INVESTORS LLC, TAX MATTERS PARTNER, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed May 12, 2021.



MEMORANDUM OPINION

These consolidated cases are before the Court on respondent's motion for partial summary judgment, and petitioners' motion for partial summary judgment. In two notices of final partnership administrative adjustment (FPAA) dated March 7, 2016, respondent disallowed reported costs of goods sold for the tax...

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