Civil Tax

In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the

Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties

As part of the Inflation Reduction Act, the IRS will receive a nearly $80 billion funding increase, including more than $45 billion for enforcement, over the next decade. Audit staff

Continue Reading Increase in IRS Funding Leading to More Audits of Public Charities

I have written before about the battles being fought by cannabis businesses facing IRS examinations.  IRS audits raise many issues for state legal cannabis businesses operating in violation of the
Continue Reading Tenth Circuit: No Fifth Amendment Defense to the Application of Section 280E

Yesterday the Tax Court issued two decisions discussing the impact of Section 280E on cannabis businesses.  One of these cases addresses the application of Section 280E to licensed and non-licensed
Continue Reading Tax Court: Section 280E Can Apply to Non-Licensed Taxpayers Engaged in Cannabis Businesses

In the latest Tax Court opinion addressing the application of Section 280E to cannabis businesses there is no good news.  However, there is some new guidance.  In Patients Mutual Assistance
Continue Reading Section 280E Litigation Update: Harsh Results for Resellers

I have recently penned a Law360 article discussing lessons learned from recent tax decisions impacting cannabis businesses.  We will continue to cover this topic on this blog.

To be alerted
Continue Reading An Update on Litigation of Cannabis Business Tax Issues