Oh man, comedy gold right there!
Thanks Jordan!
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My pleasure…I had a situation several weeks ago where I had occasion to describe to someone what it would be like if I was forced to inflict upon them what I would truly prefer not to, and I was having difficulty finding the right words to express the sense, so I found an image to convey the message.
FLEET ENEMA WITH HABENERO TABASCO
I reckon when compromise falls off of the table, you start hitting below the belt, literally. 
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Farmer Dan…I don’t have the skills you do that permit you to do what you do. However, we do have close to 1,500 clients from one end of California to the other that have entrust us with the privilege and responsibility to represent them and trust us for advice on deal with the one single thing that represents the greatest source of stress and impediment to being successful in their efforts - accounting, tax and regulatory compliance.
Unlike many practitioners, you will NEVER see me refer to myself as and expert with any of this, but, i am going to make a rare exception and share what one individual had to say about myself and my firm.
The following is taken from an email sent by Mr. Michael Savoy, CPA introducing me to a colleague:
I wanted to introduce you to Jordan Zoot, CPA who is the foremost authority within the cannabis industry in the entire United States both from the accounting perspective and the legal perspective
When you evaluate a comment, you need context to understand who is saying it. Mr. Savoy is the President of the California Board of Accountancy, the division of the California Dept. of Consumer Affairs, which is the agency that grants and oversees the licensing of every single certified public accountant in the State of California.
I am humbled and grateful for the kind words from the individuals that have the overall responsibility for a profession that I have been a part of for thirty-seven years. If you encounter a situation when our assistance might help, ASK. At this point in my career, I could have hung the cleats up close to ten years ago. The forces that motivate what we do what I can only describe as a tenacity and fire in the guts to see the commercial cannabis industry in California specifically and the United States succeed to a degree that Jeff Sessions considers “offing himself” due to viewing his miserable failure to restart the war on drugs as a disgrace from which he can NEVER recover.
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You might as well do what you you do for as long as you can do it. I have found that people who work the longest live the longest. I used to know this 96 year old man and his 70 year old son who built a working stream mill together, for fun! They were the youngest and most fit looking 70 and 90+ year olds that I have ever met, both with minds as sharp as a tack.
I appreciate the offer, and judging by what you write, though abrasive at times, you do know what you are talking about. Sometimes being sure of your knowledge comes off poorly, but we can all stand to learn something new or look at a problem from a different angle.
Currently, my father, not a licensed CPA, but he has been a financial consultant and a half dozen acronyms for decades is the one who manages our finances and taxes. So far so good, we will see what happens after our first audit. It hasn’t happened yet, but I am sure it will happen anytime now.
I would be a pretty easy client, I don’t think I have any 280E expenses, my ‘sales’ are virtually non-existent other than a phone call, and a lunch expense. 
Perhaps, I am mistaken, but it seems to be the case. 99.99% of our expenses are production related.
Anyway, my father has health issues, and we may need a someone for this area. I think a financial ‘hard ass’ (pardon my French), is a good thing. You actually remind a lot of my father.
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May I suggest that you know your business, and permit me to add that so long as a Cultivator is a cultivator, IRC Sec. 280E shouldn’t be an issue. However, maintaining proper accounting and inventory records will always be an issue. I am not sure that most people notice that substantially all of the litigation and writing about IRC Sec. 280E deal with dispensaries. Here is an article we published VERY recently that is specifically focused on the application of IRC Sec. 280E to Cultivators, Extractors, and Distributors.
Permit me to share something I would bet you have never seen in one place, a very succinct discussion of how IRC Sec. 280E applies to Cultivators.
Cultivators
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A business in California that cultivates cannabis is engaged in agricultural activity [aka “farming]2 is subject to the general rules under the tax law that apply to farmers. Simply stated, farmers that raise crops [rather than purchase crops for other uses such as feed] which complete the planting growth, and harvest for sale cycle within a calendar year are referred to as annuals. The income tax accounting rules for annuals are straightforward:
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The costs associated with structures and improvements that have a long-term useful life such as out buildings, irrigation ditches and the like are capitalized and depreciated3.
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Certain single purpose agricultural structures which are used by a farmer in a trade or business may be expensed.4
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The costs associated with conditioning and maintaining the soil, together with the cost of seed, fertilizer nutrients, labor associated with planting, trimming, tending and the actual harvesting of crops are all included in the cost of the crops which becomes part of the inventory, and when ultimately dispose of, are in Cost of Goods Sold [“COGS”].
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The costs of post-harvest breakdown of the plants between trim and flower, the placement in bulk packaging [typically “turkey bags” of approximately twenty pounds in weight] are included in inventory and ultimately COGS.
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Any Cannabis Cultivation Tax paid by the Cultivator should be included in the cost of inventory.
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Unless a Cultivator has taken steps to develop a “brand” and incurred costs for intellectual property and marketing, it would be highly unusual for a Cultivator to incur costs which would qualify as “trafficking” costs and subject to IRC Sec. 280E. It is for precisely that reason that we are very hesitant to suggest that Cultivators avail themselves of the “Micro Business” provisions and involve themselves in Distribution activities as such involvement can cause a substantial amount of expenses to become subject to IRC Sec. 280E.
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Yes, we have hit all of those bases.
That last bullet is me to a T, absolutely 0 branding. I am basically a hop farmer for craft beer.
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Great…my point in pulling it together is that for you, as a Cultivator, we think it helps to see IRC Sec. 280E framed as it applies to YOUR BUSINESS and not the industry in general.
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I don’t think that I have seen these girls lean quite so hard into the sun before. Every single plant is doing this, this is the only cultivar with folded leaves, drought stress is my guess.
We just came out of a several days worth of a heat wave. The girls got 60,000 gallons this past week, and are getting fertilized and watered today. Cooler temps on the way, they should be pumping hard as they approach transition into flower. The earliest strain (Williams Wonder) is already in pre-flower.
GG4 Leaning away from the camera.
GG4 Leaning into the camera.
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You. Are. A. BEAST!!!
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For anyone keeping score, this last application of fertilizer has brought the total to 320# of actual nitrogen per acre applied. Canada’s department of ag has put a dense crop of cannabis at 360#N/acre, right up there with corn.
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So I had my monthly copy of CBT cross my desk today…pretty freaking cool, brother! It’s nice to hold a tangible copy in my hands. I just want to reiterate how very proud we all are of you!
(shaking my head) $25 elbows…
Who has ever heard of such a thing! That’s my incredulous $25 pound face.
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‘King of Mids’
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I am also here and now claiming ‘BUDwiser’ as a Trademark.
BUDwiser ‘King of Mids’
Somebody has got to do it.
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Still waiting on my copy…I Subscribed just for this article! Congrats!!!
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I hope you get it, mine came Monday or Tuesday.
Thanks for the love. This story is 
on social media, mostly from all of the dumpster fires.
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