On March 31, 2022, the Tax Court issued the full opinion in BATS Global Markets Holdings Inc. v. Commissioner (158 T.C. No. 5). The primary issue presented in BATS Global Markets Holdings Inc. v. Commissioner was whether the petitioner's transaction fees, routing fees, and logical port fees qualify as domestic production gross receipts (DPGR) for the purpose of calculating deductions pursuant to IRC § 199. Held: No dice, BATS. Procedural Background to BATS Global Markets Holdings Inc. v. Commissioner The IRS issued a notice of deficiency determining deficiencies of $900,000 (2011), $1.3 million (2012), and $1.4 million (2013). Factual Overview of BATS Global Markets Holdings Inc. v. Commissioner During the years in issue (2011-2013) BATS Global Markets Holdings, Inc. (Bats Global) owned 100% of BATS Exchange, Inc., BATS Y-Exchange, Inc., and BATS Trading, Inc. It was the common parent of a group of corporations (collectively, the petitioner) which filed consolidated…