Lessey v. Dept. of Rev.

CourtOregon Tax Court
DecidedNovember 29, 2022
DocketTC-MD 210265G
StatusUnpublished

This text of Lessey v. Dept. of Rev. (Lessey v. Dept. of Rev.) is published on Counsel Stack Legal Research, covering Oregon Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lessey v. Dept. of Rev., (Or. Super. Ct. 2022).

Opinion

IN THE OREGON TAX COURT MAGISTRATE DIVISION Income Tax

STEPHEN LESSEY and GINGER LESSEY, ) ) Plaintiffs, ) TC-MD 210265G ) v. ) ) DEPARTMENT OF REVENUE, ) State of Oregon, ) ) Defendant. ) DECISION

Plaintiffs challenge Defendant’s adjustments to the cost of goods sold (COGS) and

expense deduction claimed on their 2016 return for their marijuana-growing business. Plaintiff

Stephen Lessey appeared and testified for Plaintiffs; Defendant was represented by its auditor,

William Swanson, and did not call any witnesses. Plaintiffs’ Exhibits 1 to 9 and Defendant’s

Exhibits A to L were admitted.

I. FACTUAL OVERVIEW

In 2016, Plaintiffs began growing marijuana for profit in a building outside Salem they

called Oak Ponds Farm (“the Farm”). The Farm was a three-room house on five acres with an

RV parked in front. Plaintiffs configured the Farm’s rooms and installed additional air

conditioning to control the temperature, lighting cycle, and water pH levels of the marijuana

cultivars at every stage of development. Mr. Lessey testified that the RV’s purpose was to

provide a bathroom and that it was not used as living quarters.

Plaintiffs’ marijuana business was primarily conducted by Mrs. Lessey, with Mr. Lessey

and Plaintiffs’ son occasionally assisting. Plaintiffs’ main source of income was Mr. Lessey’s

job with an out-of-state pharmaceutical company, which required him to travel frequently.

///

DECISION TC-MD 210265G 1 of 16 Plaintiffs and their son were registered with the Oregon Health Authority as medical marijuana

growers during 2016; Plaintiffs obtained a nonmedical marijuana license the following year.

On their 2016 return, Plaintiffs reported $19,500 in gross receipts, no beginning or ending

inventory, and $57,654 in cost of goods sold (COGS), $31,187 of which was allowed by

Defendant in its Written Objection Determination. (Exs C at 2–3; J at 3.) Most of the expenses

now in dispute were originally claimed by Plaintiffs within the COGS: expenses for air

conditioning units, cellular telephone service, internet service, office rental, and meals and

entertainment. Besides the COGS, Plaintiffs claimed a $9,596 car-and-truck expense deduction

on their Schedule C. (Ex C at 2.) Evidence pertinent to the disputed expenses and adjustments

will be described where relevant in the analysis below.

Plaintiffs seek to have the disallowed expenses either excluded or subtracted from their

taxable income, while Defendant asks the court to uphold its adjustments. At a prior hearing,

Defendant had stated it might challenge Plaintiffs’ stated income and previously allowed

expenses, but it did not develop such a challenge at trial.

Plaintiffs also seek a court order awarding them $2,000 for “consulting services”

provided by Mr. Lessey at the initial audit meeting. (Ex 7.) Mr. Lessey alleges Defendant’s

auditor scheduled the meeting to review receipts, but instead asked questions about the marijuana

industry and told Mr. Lessey he would review the receipts later. Mr. Swanson alleges

Mr. Lessey “provided no services to the Oregon Department of Revenue.” (Ex B at 3.)

II. ANALYSIS

The principal issue in this case is the includability of the disputed expenses in Plaintiffs’

taxable income. On their return, Plaintiffs excluded most of the expenses as part of the COGS,

implicitly characterizing them as capital investments in inventory. Plaintiffs now claim the

DECISION TC-MD 210265G 2 of 16 Oregon subtraction for marijuana business expenses otherwise deductible but for section 280E of

the Internal Revenue Code (IRC). Because Plaintiffs seek affirmative relief, they must bear the

burden of proof on all factual questions. See ORS 305.427. 1

Plaintiffs’ additional claim for a consulting fee is outside the jurisdiction of this court

because it neither affects nor is affected by Plaintiffs’ tax liability. This court’s jurisdiction lies

over “all questions of law and fact arising under the tax laws of this state.” ORS 305.410(1). To

fall under that statute, a claim must have “some bearing on tax liability.” Sanok v. Grimes, 294

Or 684, 701, 662 P2d 693 (1983). Any obligation of Defendant to pay Plaintiffs for services

rendered would arise under the law of contracts or of torts, not under the tax laws.

A. Cost of Goods Sold in Marijuana Production

Expenses within the COGS are excluded from gross income rather than deducted from it.

Max Sobel Wholesale Liquors v. Comm’r, 630 F2d 670, 671–72 (9th Cir 1980). That occurs

because gross receipts from sale of inventory are not income to the taxpayer until the cost of the

inventory sold is recovered: “The ‘cost of goods sold’ concept embraces expenditures necessary

to acquire, construct or extract a physical product which is to be sold; the seller can have no gain

until he recovers the economic investment that he has made directly in the actual item sold.”

Reading v. Comm’r, 70 TC 730, 733 (1978), aff’d 614 F2d 159 (8th Cir 1980); see Treas Reg

§ 1.61–3(a) (defining gross income as “total sales, less the cost of goods sold, plus any income

from investments and from incidental or outside operations or sources”). Only expenses

attributable to acquiring inventory can be part of the COGS.

1 The court’s references to the Oregon Revised Statutes (ORS) are to 2015. The statute establishing the court’s jurisdiction has not since been changed.

DECISION TC-MD 210265G 3 of 16 The distinction between excluding and deducting expenses is of special importance to

marijuana businesses because they are forbidden from claiming deductions by IRC section

280E. 2 Nevertheless, IRC section 280E does not prevent them from excluding the inventory

costs of controlled substances from gross income. Patients Mut. Assistance Collective Corp. v.

Comm'r, 151 TC 176, 207–10 (2018) (Patients Mutual), aff’d, 995 F3d 671 (9th Cir 2021).

Federal tax law has two sets of rules for determining the inventory costs that constitute

the COGS: sections 471 and 263A of the IRC. Because IRC section 263A does not apply to

costs that “could not be taken into account in computing [federal] taxable income for any taxable

year[,]” taxpayers barred from claiming deductions by IRC section 280E determine the COGS

under IRC section 471. IRC § 263A(a)(2) (Dec 18, 2015); Patients Mutual, 151 TC at 209–10.

Taxpayers who produce their inventory instead of buying it include both direct and

indirect costs “incident to and necessary for production” in their inventory accounting. Treas

Reg § 1.471-11(b)(1). Direct production costs are “components of the cost of either direct

material or direct labor”—i.e., material either consumed or made an integral part of the product

and labor associated with producing particular batches of product. Treas Reg § 1.471-11(b)(2).

Indirect production costs are all other production costs besides direct production costs. Treas

Reg § 1.471-11(b)(3)(i).

Further guidance on indirect production costs is found in nonexclusive lists of examples.

See Treas Reg § 1.471-11(c). Expenses for repair, maintenance, utilities, and rent (among

others) are generally inventory costs—“to the extent, and only to the extent, such costs are

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Related

Fausner v. Commissioner
413 U.S. 838 (Supreme Court, 1973)
Sanok v. Grimes
662 P.2d 693 (Oregon Supreme Court, 1983)
Patients Mutual Assistance v. Cir
995 F.3d 671 (Ninth Circuit, 2021)

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