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SAN JOSE WELLNESS v. COMMISSIONER

Docket Nos. 12313-15, 12353-15, 15714-18.

156 T.C. 62 (2021)

156 T.C. No. 4

SAN JOSE WELLNESS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 17, 2021.

Attorney(s) appearing for the Case

Henry G. Wykowski , Katherine L. Allen , and James Brooks Mann , for petitioner.

Nicholas J. Singer and Julie Ann Fields , for respondent.

OPINION

Section 280E1 of the Internal Revenue Code (the "Code") provides that "[n]o deduction * * * shall be allowed for any amount paid or incurred during the taxable year in carrying on any trade or business if such trade or business (or the activities which comprise such trade or business) consists...

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