- 13 - ! The $2,185 deducted for security reflects the cost of security at the main facility, including the costs of an alarm company and medical service. ! The $660 deducted for supplies reflects the costs petitioner incurred to buy various supplies. ! The $7,870 deducted for telephone reflects the cost petitioner incurred for its telephone service. ! The $18,514 deducted for utilities reflects the cost of the gas and electricity petitioner used at its main facility. OPINION The parties agree that during the subject year petitioner had at least one trade or business for purposes of section 280E. According to respondent, petitioner had a single trade or business of trafficking in medical marijuana. Petitioner argues that it engaged in two trades or businesses. Petitioner asserts that its primary trade or business was the provision of caregiving services. Petitioner asserts that its secondary trade or business was the supplying of medical marijuana to its members. As to its trades or businesses, petitioner argues, the deductions for those trades or businesses are not precluded by section 280E in that the trades or businesses did not involve “trafficking” in a controlled substance. Respondent argues thatPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 NextLast modified: November 10, 2007