How it works

A right-sized engagement, start to finish.

Ten minutes on the phone, a couple of documents you already have, and a $375 audit that tells you what §280E has been costing you. Then it's off your plate.

What §280E costs you

Under §280E, you're taxed on gross profit — not net.

70–80%

The effective federal tax rate operators still under §280E carry. No deductions for rent, payroll, or marketing — only cost of goods survives.

Only COGS survives
6 yr

How far back the IRS can assess when a return understates income by more than 25% — and with no limit at all if a return was never filed.

§6501(e)
$10k

The single cash transaction that triggers a Form 8300 filing. Miss it as an unbanked operator and the penalties stack fast.

§6050I
The engagement

Four steps, and it's off your plate.

01 · Ten-minute call

We talk about your designation, how your medical and adult-use revenue splits, and how you file today. That's usually enough for me to tell you whether Schedule III moves anything for you — and whether I'm the right fit. If I'm not, I'll say so on that call, not after an engagement letter.

02 · You send the basics

Last year's return and a rough P&L. If your books are live somewhere, point me at them instead. I'm not asking you to assemble a package — I'd rather see what you actually have, as it actually is.

03 · You start with the $375 audit

You get a clear number — what §280E cost you each year, and what the transition is worth — and a plan for the work that follows. From there it's off your plate: fixed fee, signed by an EA, and built to hold under exam.

04 · I sign and represent

From there I carry the lane — signing, filing, and standing in front of the IRS if a notice comes. You get documented positions, clear updates, and a defense file you can rely on. You keep running your business.

What I handle

The work I take off your plate.

Priced per engagement, or as an ongoing review. Bring me in for one filing or your whole tax year.

§471(c) · 8275

Return signing & filing

Your business and personal returns, prepared and signed under my Enrolled Agent credential, with a written COGS / 471(c) position and a Form 8275-R disclosure — so an aggressive-but-defensible deduction is protected, not exposed.

Signed & filed
§471-11

280E / COGS cost review

Your production and inventory costs recomputed into full-absorption workpapers — cultivation, manufacturing, or retail — so every dollar the law lets you capitalize lands in COGS, and nothing that shouldn't.

Workpaper
Sched. III

Schedule III transition planning

Your medical-vs-adult-use split analyzed, and amended-return and retroactive-relief options evaluated as IRS guidance lands. The 2026 window changes what you owe — this is where you claim it.

Advisory
§7602

Audit defense & appeals

If a notice comes, I answer it: IDR responses, rebuilding records from your bank, POS, and Metrc, and the protest to Appeals if it goes that far. I stand in front of the IRS, not you.

Per engagement
§6321 · §6331

Collections & relief

Liens, levies, installment agreements, Currently Not Collectible, Offers in Compromise, and penalty abatement — the full resolution toolkit if you're already behind.

Per engagement
§6050I

Form 8300 & cash compliance

Cash-reporting cleanup for unbanked operators, a simple SOP so it stops recurring, and a defense when the $10k-cash penalties surface.

SOP + defense
§6672

Payroll & trust-fund defense

Deposit compliance for cash-payroll operators, and defense against the Trust Fund Recovery Penalty — the one that reaches you personally.

Defense
What you receive

The work product, not a promise.

Every engagement produces a defined, signed deliverable that lands in your portal. Here's exactly what the work looks like.

§471(c) · Form 8275-R

471(c) disclosure, filed

Your reasonable-basis COGS position, disclosed on the return with the authorities behind it.

OutcomeAn aggressive deduction that's penalty-protected, not exposed — and a signer who stands behind it.
§471-11 · Workpaper

280E / COGS review

A per-vertical, full-absorption workpaper showing every defensible dollar of COGS, and what's excluded.

OutcomeThe lowest legal tax under §280E, documented to survive an exam.
§6050I · Form 8300

Form 8300, handled

Cash-report filing and cleanup, with a go-forward SOP.

OutcomeNo surprise $27k+ cash-reporting penalty, and books that are exam-ready.
§6672 · Advisory

Trust-fund defense

A responsible-person screen and deposit fixes before the penalty reaches you personally.

OutcomeYou shielded from personal liability, and payroll deposits made compliant.
How it's delivered

One pipeline. Every engagement runs the same seven phases.

You always know where your work stands — tracked in your secure portal from first upload to final filing.

01

Intake

Your matter captured, and the exposure identified.

02

Scope

Engagement confirmed; the position and disclosure path set.

03

Records

What I need collected: bank, POS, Metrc, payroll.

04

Draft

Your deliverable built; workpapers and disclosures prepared.

05

File

Signed, filed, or submitted to the IRS on your behalf.

06

Review

Checked against current statute and case law; your report issued.

07

Close

Outcome validated, next step logged, support window open.

Nothing is "done" until the outcome is validated. Every phase has a defined finish line, so your work never stalls or disappears into email.

The practitioner

A credential you can put on your Power of Attorney.

An Enrolled Agent is federally licensed to represent any taxpayer, for any tax matter, before every office of the IRS — in all 50 states. That's the authority a 471(c) position needs behind it, and the authority that lets me stand in for you if the IRS ever calls.

Every aggressive position is disclosed, not hidden. Every year is checked against current case law and statute before I tell you it's closed. Nothing goes to the IRS without verification — and nothing about your business moves to any third party or AI tool without your written §7216 consent.

Admitted before the IRS

Represent, sign, and file in all 50 states — exam, appeals, and collections.

Disclosure-gated method

Form 8275 / 8275-R on aggressive positions — penalty protection built in, not bolted on.

Cannabis-native

Per-vertical COGS, cash-heavy 8300 exposure, and trust-fund risk — the traps generalists miss.

How we work

Everything runs inside one secure portal.

You work in a private, encrypted portal — intake, documents, deliverables, and status in one place. Your PII stays access-controlled and audit-ready, from the first upload to the final filing.

  • One login, full history — nothing in email.
  • PII access-controlled from intake to delivery.
  • Every deliverable tracked, versioned, and logged.
  • AI-assisted where it speeds the work — never without your §7216 consent, never outside the portal.

Prepared & e-filed in Drake Tax

Professional tax software · US-based support.

Why now

The rules are moving. This is the moment to get your positions right.

DEC 2025

Executive order

The White House directs DOJ to reschedule medical marijuana "expeditiously."

APR 2026 · NOW

Medical → Schedule III

State medical-licensed operators leave §280E for tax year 2026. Retroactive relief under review.

JUL 2026

Broader hearing

The DEA hearing on rescheduling all marijuana concludes. Outcome pending; challenges expected.

STILL LIVE

Adult-use stays stuck

Recreational and unlicensed activity stay Schedule I — §280E still applies. Most operators still need a defense.

Straightforward pricing

Every engagement starts with the $375 280E Risk Review.

It tells you exactly what §280E cost you, and it's credited toward the work that follows.

Start with the $375 280E Risk Review — credited toward your engagement. I scope the exposure before either of us commits.

Prices cover defined scope. A matter that escalates into a full exam, Appeals, or collections is scoped separately, so a fixed fee never rides on open-ended risk. This is general information, not legal or tax advice; representation begins only under a signed engagement.

Common questions

How it works, answered.

Do I qualify?

This is built for cannabis operators in every legal state — dispensary, cultivation, or mixed medical/adult-use. If that's you and you're still filing under §280E, the $375 audit is where we start.

What does the $375 audit tell me?

A clear number: what §280E has cost you each year, what Schedule III changes for your license type, and a plan for the work that follows. If the transition doesn't move anything for you, I'll say so — and you've spent $375 to know, not thousands to find out.

Whose signature goes on the return?

Mine, as the Enrolled Agent preparing and signing under a defined engagement. That's the point — your return carries a credentialed signature admitted to practice before the IRS, with the disclosure to back the position.

I'm already in an audit — can you still help?

Yes. Power of Attorney goes on file, then I take over the IDR responses, the substantiation file, Appeals, or the levy/lien/installment work — as a standalone engagement, no return-prep relationship required.

What does Schedule III change for me?

Rescheduling has changed the picture for some license types, but §280E still governs most operators' current-year returns, and the details depend on your license and your state. We run that analysis for your situation, and evaluate amended returns once IRS guidance is final.

How fast do you respond?

Within one business day. IRS deadlines don't wait — a missed IDR or a 30-day letter is how a manageable case turns into an expensive one.

Talk to a licensed EA

See what §280E is really costing you.

Book a 30-minute consult with an Enrolled Agent — no obligation.