Tax lawyers and risk specialists, however, caution that this choice is likely to start a protracted and costly legal battle with the IRS, which might result in fines of millions of dollars on top of already outstanding tax obligations. “As the saying goes, if something sounds too good to be true, it usually is,” said San Francisco-based tax attorney Henry Wykowski, who has represented several significant 280E-related cases before federal tax courts. “We believe this more aggressive strategy is reckless and will ultimately backfire on those who are pursuing it.”