General Tax Controversy News & Updates

The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements
Continue Reading Conservation Easements: A Year End Review

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

We recently wrote on the new proposed regulations addressing the availability of charitable deductions when taxpayers receive or expect to receive corresponding state or local tax credits for contributions.  The
Continue Reading IRS Provides Clarification for Business Taxpayers That Make Payments To State or Local Tax Credit Programs

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

Attorneys representing cannabis businesses are often faced with questions about what happens when the cannabis business has not paid its taxes and the IRS is proceeding with collection actions.  No
Continue Reading IRS Guidance to Field: Deep Clean Equipment Used in Cannabis Businesses Before Selling

In Wendell Falls Development, LLC v. Commissioner, T.C. Memo. 2018-45, the Tax Court denied a charitable contribution deduction for a taxpayer’s contribution of a conservation easement because the taxpayer
Continue Reading Conservation Easements: Charitable Deduction Disallowed Under “Substantial Benefits” Test