Opinion
21146-15
02-09-2022
TBL Licensing LLC f.k.a. The Timberland Company, and Subsidiaries (A Consolidated Group) Petitioner v. Commissioner of Internal Revenue Respondent
ORDER AND DECISION
James S. Halpern, Judge
Pursuant to the determination of this Court as set forth in its Opinion (158 T.C. No. 1) filed January 31, 2022, it is
ORDERED that petitioner's motion for summary judgment filed July 19, 2019, is denied. It is further
ORDERED that respondent's motion in limine filed September 16, 2019, is denied as moot. It is further
ORDERED that respondent's motion to strike filed September 16, 2019, is denied as moot. It is further
ORDERED that respondent's motion for summary judgment filed July 19, 2019, is granted. It is further
ORDERED AND DECIDED that respondent's deficiency, as asserted in the Statutory Notice of Deficiency dated May 11, 2015, is sustained.