Patients Mutual Assistance Collective Corporation d.b.a. Harborside Health Center v. Commissioner

151 T.C. No. 11

UNITED STATES TAX COURT PATIENTS MUTUAL ASSISTANCE COLLECTIVE CORPORATION d.b.a. HARBORSIDE HEALTH CENTER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 29212-11, 30851-12, Filed November 29, 2018. 14776-14.1 California medical-marijuana dispensary P deducted I.R.C. section 162 business expenses and adjusted for indirect COGS per the I.R.C. section 263A UNICAP rules for producers. R determined that P’s sole trade or business was trafficking in a controlled substance and that I.R.C. section 280E prevented it from deducting business expenses. R also…