As discussed in more detail in my prior post, Alpenglow Botanicals (“Alpenglow”) is a state licensed Marijuana dispensary based in Colorado. Alpenglow was audited for several tax years and the IRS made adjustments, denying...more
4/3/2019
/ Business Expenses ,
Business Taxes ,
Controlled Substances Act ,
Criminal Penalties ,
Dispensaries ,
Eighth Amendment ,
Internal Revenue Code (IRC) ,
IRC Section 280E ,
IRS ,
Marijuana Related Businesses ,
Petition for Writ of Certiorari ,
Qualified Business Income ,
Tax Deductions ,
Tax Liability
- Both Code sections end with a capital letter.
- Both are in Subchapter B.
- Both have to do with deductions.
- Both treat certain types of businesses differently than others for no good reason.
-...more
It’s a new year, but why not live in the past just long enough to talk briefly about that last couple of Section 280E cases that trickled in at the end of 2018? Today, I’m reviewing the two Harborside cases....more
1/23/2019
/ Audits ,
Controlled Substances Act ,
Corporate Taxes ,
Dispensaries ,
Drug Trafficking ,
Internal Revenue Code (IRC) ,
IRC Section 280E ,
Marijuana ,
Marijuana Related Businesses ,
Medical Marijuana ,
Res Judicata ,
Tax Court
If you read my most recent post on Section 280E of the Internal Revenue Code, you might have picked up on my disappointment with the Alpenglow opinion. Whether the conclusion is right or wrong, in my estimation, it could have...more
11/7/2018
/ Appeals ,
Business Taxes ,
Compassionate Use Act ,
Controlled Substances Act ,
Drug Trafficking ,
IRC Section 280E ,
IRS ,
Marijuana Related Businesses ,
Public Policy ,
Statutory Authority ,
Tax Credits ,
Tax Deductions ,
TEFRA
Today, we’re picking up right where we left off last week, shedding more light on Section 280E by examining some of the noteworthy cases (and one memo) that have come to define it....more
It’s been a busy summer for cannabis business Section 280E controversy, with three published cases (Alterman v. Commissioner; Loughman v. Commissioner; and Alpenglow Botanicals, LLC v. U.S.) construing the statute, and...more