JONATHAN KALINSKI Quoted in Tax Notes
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Wednesday, July 26, 2023
Jonathan Kalinski quoted in Tax Notes article on newly filed Tax Court cases challenging the IRS’ position in applying IRC Section 280E to Offers in Compromise for marijuana businesses. Offers in Compromise are challenging for marijuana businesses because the IRS uses 280E disallowed expenses in determining collection potential, creating a phantom cash problem.
“The fiction of ignoring taxpayer expenses for considering an OIC makes no one’s life easier as the IRS struggles to collect phantom cash and the taxpayer struggles to pay it.”
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