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the health of the user. See United States v. Oakland Cannabis
Buyers’ Coop., 532 U.S. 483 (2001).
Respondent argues that petitioner, because it trafficked in
a controlled substance, is not permitted by section 280E to
deduct any of its expenses. We disagree. Our analysis begins
with the text of the statute, which we must apply in accordance
with its ordinary, everyday usage. See Conn. Natl. Bank v.
Germain, 503 U.S. 249, 253-254 (1992). We interpret that text
with reference to its legislative history primarily to learn the
purpose of the statute. See Commissioner v. Soliman, 506 U.S.
168, 174 (1993); United States v. Am. Trucking Associations,
Inc., 310 U.S. 534, 543-544 (1940); Venture Funding, Ltd. v.
Commissioner, 110 T.C. 236, 241-242 (1998), affd. without
published opinion 198 F.3d 248 (6th Cir. 1999); Trans City Life
Ins. Co. v. Commissioner, 106 T.C. 274, 299 (1996).
Congress enacted section 280E as a direct reaction to the
outcome of a case in which this Court allowed a taxpayer to
deduct expenses incurred in an illegal drug trade. See S. Rept.
97-494 (Vol. 1), at 309 (1982). In that case, Edmondson v.
Commissioner, T.C. Memo. 1981-623, the Court found that the
taxpayer was self-employed in a trade or business of selling
amphetamines, cocaine, and marijuana. The Court allowed the
taxpayer to deduct his business expenses because they “were made
in connection with * * * [the taxpayer’s] trade or business and
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