In Uncategorized on 02/22/2021 at 15:52

One can almost hear the weariness in Judge Mark V. Holmes’ voice as he dictates the opinion in Desert Organic Solutions, 2021 T. C. Memo. 22, filed 2/22/21.

The Desert Organists are potters seeking Section 162 ordinary-and-necessaries for their CA-legal pottery.

You can almost hear Judge Holmes’ pleading falling upon IRS’ deaf ears. “In Patients Mutual Assistance Collective Corp. v. Commissioner, 151 T.C. 176 (2018), appeal filed, No. 19-73078 (9th Cir. Dec. 3, 2019), we extensively analyzed the taxation of this still relatively new industry. Patients Mutual is currently on appeal to the Ninth Circuit. We’d suggested to the parties that it might be sensible to wait to see what happens to that appeal before taking this case to decision, but the Commissioner disagreed.” 2021 T. C. Memo. 22, at p. 2.

Of course I’d blogged Patients Mutual. See my blogpost “The War on Drugs,” 11/29/18.

So the Desert Organists ask for everything, they and IRS stip to a different everything, and Judge Holmes decides some kind of everything.

Wherefore, we have a three-page T. C. Memo., contending for the shortest of the year.




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