- 23 - 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.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23Last modified: November 10, 2007