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marijuana. The evidence at hand permits an allocation of
expenses to those activities. Although the record may not lend
itself to a perfect allocation with pinpoint accuracy, the record
permits us with sufficient confidence to allocate petitioner’s
expenses between its two trades or businesses on the basis of the
number of petitioner’s employees and the portion of its
facilities devoted to each business. Accordingly, in a manner
that is most consistent with petitioner’s breakdown of the
disputed expenses, we allocate to petitioner’s caregiving
services 18/25 of the expenses for salaries, wages, payroll
taxes, employee benefits, employee development training, meals
and entertainment, and parking and tolls (18 of petitioner’s 25
employees did not work directly in petitioner’s provision of
medical marijuana), all expenses incurred in renting facilities
at the church (petitioner did not use the church to any extent to
provide medical marijuana), all expenses incurred for “truck and
auto” and “laundry and cleaning” (those expenses did not relate
to any extent to petitioner’s provision of medical marijuana),
and 9/10 of the remaining expenses (90 percent of the square
footage of petitioner’s main facility was not used in
petitioner’s provision of medical marijuana).6 We disagree with
6 While we apportion most of the $212,958 in “Total
deductions” to petitioner’s caregiving services, we note that the
costs of petitioner’s medical marijuana business included the
$203,661 in labor and $43,783 in other costs respondent conceded
(continued...)
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