Tax Controversy Litigation

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

Ian M. Comisky and Matthew D. Lee have authored a Journal of Taxation article entitled “IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions.” In their article, Ian and Matt
Continue Reading IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions

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

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

Recently, the written supervisory approval requirement of Section 6751(b) has been one of the primary issues in Tax Court litigation concerning penalties that the IRS has asserted against taxpayers. The
Continue Reading Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding