In the recent United States Tax Court case O’Connor v. Commissioner of Internal Revenue, Judge Arbeit sanctioned the petitioner for advancing frivolous arguments contesting the authority of the IRS to assess tax....more
The U.S. tax system developed in response to colonial opposition to taxation without representation. As such, Article I of the Constitution provides that Congress may not impose a “direct tax” unless the tax is “apportioned”...more
Cannabis (or marijuana) dispensaries have long stated that they are subjected to harsher tax consequences under the Internal Revenue Code (“IRC” or “Code”) than their “legal” counterparts. Specifically, they have argued, in...more
As more and more states are allowing legal use of marijuana, medical marijuana businesses are faced with large tax bills because of marijuana’s continued classification as a Schedule I controlled substance under federal law. ...more