There will still be raids.
Any time they think they broke any other federal law, they will raid them. They also did not say anything about filing your taxes illegally. It is illegal in tax code to claim any income from selling pot, or from a dispensary. So there is still this loop hole in the law and letter the DOJ sent out.
The IRS will not do a audit until the DEA clears the building.
Not exactly. It's legal to claim income and pay taxes on a federal crime, it's just illegal to take any deductions on it. That's the harborside issue. The IRS says it's ok for them to claim income, but they can't claim payroll deductions on budtenders.
Either way, I don't think we will see the IRS being used as a weapon any longer. They got in some trouble with that. Republicans complained about Tea Party organizations being unfairly targeted by the IRS but when they looked into it a little more they also noticed that collectives were being unfairly targeted. Complains were made by congressional democrats.
I think we've seen an end to the raids for the most part. Since the election ended no new letters have been sent to landlords and a lot of the letters that were sent out right before the election got ignored and there were no penalties. I know of several dispensaries that got letters from the DEA saying that they needed to close or face a prison sentence but continued to stay open. Nothing happened.
There weren't actually a whole lot of prosecutions that came out of this last round of DEA letters. BPG, Richard Lee, and Harborside got in some trouble, but not many more than that. There weren't actually very many raids. Most of the clubs that got raided were the high profile ones who decided they wanted to put themselves on TV.
If there is more DEA action, IMO they will be limited in scope to dispensaries who run their mouths off on TV or are within 1200 ft of a school. Other than that I think dispensaries are pretty safe in Cali. I think Colorado and Washington can expect a round of similar actions where most of the DEA letters will be empty threats but they'll single out a couple high profile clubs to make an example out of them.
I think it's going to be nearly impossible for the DEA to target medical dispensaries in California while allowing for profit non-medical businesses to exist in two states.