Sustainable Forests, LLC v. Alabama Department of Revenue.

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 of real property to each of the LLCs. That same month, the tax*271payer executed assignments of its interests in timberland leases to each of…