May 12, 2021 2021-0965 Tax Court holds mining company can't deduct estimated drilling costs as cost of goods sold, absent any gross receipts from the sale of goods In BRC Operating Co. LLC, et al. v. Commissioner, T.C. Memo. 2021-59 (May 12, 2021), the Tax Court has granted partial summary judgment for the IRS, sustaining the Service's disallowance of deductions for estimated drilling costs that a mining company claimed as cost of goods sold. To recover cost of goods sold, an entity must have gross receipts from the sale of goods to offset, the court concluded. ——————————————— ATTACHMENT BRC Operating et al v Commissioner 
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