On May 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Richmond Patients Group v. Commissioner (T.C. Memo. 2020-52). The issues before the court in Richmond Patients Group v. Commissioner were (1) whether the petitioner is entitled to additional costs of goods sold or deductions for business expenses; (2) whether the petitioner was a reseller or a producer of marijuana pursuant to IRC § 471 during the years in issue; (3) whether the petitioner is allowed to change its accounting method pursuant to IRC § 446 for tax year 2015; and (4) whether the petitioner is liable for accuracy-related penalties pursuant to IRC § 6662(a). Background to Richmond Patients Group v. Commissioner The petitioner was a members-only medical marijuana dispensary. It offered no other services, therapeutic or otherwise, just the reefer. When the petitioner purchased bulk marijuana, it paid the seller a 25% to 50% down payment…