Californians Helping to Alleviate Medical Problems, Inc. - Page 23




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          respondent that petitioner must further justify the allocation of           
          its expenses, reluctant to substitute our judgment for the                  
          judgment of petitioner’s management as to its understanding of              
          the expenses that petitioner incurred as to each of its trades or           
          businesses.  Cf. Boyd Gaming Corp. v. Commissioner, 177 F.3d 1096           
          (9th Cir. 1999), revg. T.C. Memo. 1997-445.                                 
               All arguments by the parties have been considered.  We have            
          rejected those arguments not discussed herein as without merit.             
          Accordingly,                                                                

                                                  Decision will be entered            
                                             under Rule 155.                          

















               6(...continued)                                                        
          to have been properly reported on petitioner’s tax return as                
          attributable to cost of goods sold in the medical marijuana                 
          business.                                                                   






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