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
Section 280E Litigation Update: Harsh Results for Resellers
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
An Update on Litigation of Cannabis Business Tax Issues
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
Section 280E and the Harsh Reality of Double Taxation
There is not too much to say about the Tax Court’s latest decision involving a marijuana company. In Loughman v. Commissioner, T.C. Memo 2018-85, the operators of a Colorado
Continue Reading Section 280E and the Harsh Reality of Double Taxation
The High Tax Compliance Burden For Cannabis Businesses
Yesterday, the Tax Court issued its opinion in Alterman v. Commissioner, T.C. Memo 2018-83. This case involved the operation of a medical marijuana dispensary which was reported on Schedule
Continue Reading The High Tax Compliance Burden For Cannabis Businesses
Tax Court Holds Commissioner Failed to Comply with Supervisor Approval Requirement for Fraud Penalty
In Graev III, issued late last year, the Tax Court held that the Commissioner must comply with section 6751(b)(1) as part of his burden of production for tax penalties.
Continue Reading Tax Court Holds Commissioner Failed to Comply with Supervisor Approval Requirement for Fraud Penalty
Conservation Easements: Charitable Deduction Disallowed Under “Substantial Benefits” Test
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
Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding
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
Philadelphia Chapter of FBA Tax Section to Host Tax Court Judge Mark Holmes on May 30
On May 30, the newly-formed Philadelphia Chapter of the Federal Bar Association’s Section on Taxation will host a meet-and-greet event with the Honorable Mark V. Holmes of the United States
Continue Reading Philadelphia Chapter of FBA Tax Section to Host Tax Court Judge Mark Holmes on May 30
United States Tax Court Announces Election of New Chief Judge
Earlier this week the United States Tax Court announced that Judge Maurice B. Foley has been elected Chief Judge to serve a two-year term beginning on June 1, 2018.
Judge
Continue Reading United States Tax Court Announces Election of New Chief Judge