This article is part of our ongoing series documenting the early history of Oregon’s legal psilocybin program. While the headlines focused on ballot measures, rulemaking, and the first service centers, another crucial story unfolded behind the scenes: how businesses would survive the financial and legal realities of federal tax law.
At the center of that story stands Justin Botillier, founder of Calyx CPA, whose contribution to Oregon’s psilocybin industry was both timely and essential. Without his insights and willingness to educate others, many service centers might never have gotten off the ground.
Entering at a Critical Moment
When Measure 109 passed in 2020, Oregon became the first state in the U.S. to create a regulated psilocybin services framework. But while excitement was high, reality soon set in: psilocybin remained a Schedule I controlled substance under federal law. That meant every operator would face the crushing weight of IRS Section 280E, which disallows most business deductions for entities involved with Schedule I or II substances.
For aspiring service centers, this was not a theoretical problem—it was a threat to survival. The risk was clear: a 21% federal tax on gross revenue, leaving no path to profitability.
This is where Justin entered the scene. Already seasoned from over a decade in the cannabis industry, he knew the traps hidden in 280E—and he knew there were ways to mitigate them.
Translating Cannabis Precedent to Psilocybin
While lawyers and accountants cautiously floated conservative ideas, Justin introduced the psilocybin community to two powerful tools:
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The CHAMPS Precedent
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A landmark tax court case, California Helping Alleviate Medical Problems (CHAMPS), established that service-based businesses distributing medical cannabis could still claim deductions tied to their services.
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Justin recognized that Oregon psilocybin centers were, at their core, service providers. Facilitation, safe facilities, and preparation/integration support aligned closely with CHAMPS’ arguments—and that precedent could protect psilocybin operators.
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IRS Code Section 471(c)
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A provision few accountants were even aware of, 471(c) allowed small businesses to account for inventory costs in ways that softened the blow of 280E.
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For psilocybin, it was a lifeline. Combined with CHAMPS, it created a viable strategy for keeping doors open.
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These approaches were not risk-free, but they were far more sustainable than the “play it safe” strategies that would have bankrupted most operators within a year. As one early service center operator reflected, “I think probably all of the service centers use 471(c). Otherwise, I don’t know how they could exist.”
Justin continues to write about psilocybin taxation and the challenges of 280E through his firm, Calyx CPA. One example is his article, Can Magic Mushroom Companies Successfully Challenge 280E?, which explores how these precedents may evolve as the industry grows.
Building a Community of Knowledge
What made Justin’s role even more impactful was his willingness to teach, not just consult. He quickly organized free online seminars where he laid out what he knew about CHAMPS, 280E, cannabis case law, and how these lessons could apply to psilocybin.
Other accountants, hoping to land clients, guarded their information. Justin shared his openly. He engaged directly with service center founders, fielding tough questions, refining his advice, and adapting strategies in real time.
By the time the first tax season arrived, his firm had filed returns for a dozen psilocybin service centers—giving him a vantage point no one else had.
More Than Numbers
Justin’s impact went beyond technical expertise. His personal relationship with psychedelics, going back to his first psilocybin experience as a teenager, gave him a deep sense of connection to the movement.
“Doing taxes is lame,” he once admitted with a smile, “but working with business owners and helping them contribute to something that’s on the right side of history—that’s a dream.”
That sense of purpose infused his work. For him, helping psilocybin service centers survive was more than a professional challenge—it was a way of contributing to healing, justice, and the broader evolution of consciousness.
An Indelible Contribution
The Oregon psilocybin program was built by many hands. Some drafted legislation. Some fought for rules. Some opened the first centers. And some, like Justin Botillier, made sure those centers could pay their bills, file their taxes, and withstand IRS scrutiny.
His early and generous contributions gave the industry financial footing, set a model for Colorado and other states to follow, and embodied the spirit of collaboration that defines the best of this movement.
His work may not make headlines, but it made the difference between survival and collapse for many service centers.
For more about 280E, check out Justin’s blog: Can Magic Mushroom Companies Successfully Challenge 280E?
