Tax

Building Maximum Defensible Cost of Goods Sold

Under Section 280E, cost accounting is tax planning. This guide walks through how to capture every cost the regulations permit — and how to document it so the position survives.

Start with labor

Payroll is usually the largest capitalizable cost and the most commonly wasted one. Code hours to function at the pay-run level: cultivation, harvest, trim, extraction, packaging, quality control, then retail and administration separately. Reconstructing this at year end from memory produces a number nobody can defend.

Allocate facility costs on a written basis

Rent, utilities, depreciation and maintenance attributable to production space are capitalizable. Square footage is the common allocation basis; metered utility data is stronger where available. Whatever you choose, write it down and apply it consistently.

Indirect production costs people forget

  • Production supervision and management time spent in production areas
  • Quality control, compliance testing and remediation tied to batches
  • Equipment repairs, maintenance and depreciation on production assets
  • Inbound freight and receiving labor
  • Production supplies, packaging used in the production process

The documentation standard

Every costing position should have a method memo, an allocation basis with supporting data, batch-level detail, and a reconciliation to Metrc. If those four exist, an examination is a document request. If they do not, it is a negotiation.

Questions

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