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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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Last modified: November 10, 2007