Nick and Helen Kikalos - Page 10

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          competitor to bring a lawsuit.  In general, the competition was             
          such that petitioners' competitors could expect profits of                  
          between $.10 and $1 per carton.  Competitors who were some miles            
          away from the Illinois border marked up their cigarettes by 10 to           
          15 percent.                                                                 
               Petitioners' Federal income tax returns for the years in               
          issue were prepared by professional accountants, based upon                 
          information furnished them.  The accountants did not conduct an             
          audit of petitioners' business activities, nor did they establish           
          other inventory or cash controls.                                           
               For the years in issue, petitioners' Federal income tax                
          returns reported gross sales from Nick's Liquors ranging between            
          $8,535,458 and $9,054,086 per year.  These returns reported                 
          taxable income from operations of $500,698 for 1990, $543,245 for           
          1991, and $531,549 for 1992.  In each instance, the amounts                 
          reported represented gross margins on sales of approximately 6              
          percent. Respondent determined that petitioners had understated             
          their taxable income.  Respondent accordingly redetermined                  
          petitioners' income for the years in issue by utilizing the                 
          "percentage markup method".  Respondent's method results in                 
          application of gross profit margins of approximately 26.8 percent           
          for the years in issue.  Respondent based that redetermination on           
          margins in a report entitled, "Estimated Gross Margin as Percent            
          of Sales, by Kinds of Business", printed in the Combined Annual             
          and Revised Monthly Retail Trade reports issued by the U.S.                 




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