- 14 - of goods sold, respondent asserted that petitioners had gross receipts in 1993 of $102,000, as stated in the 1993 amended return (a markup of 66.5 percent). Petitioners argue that respondent's markup percentage is excessive. They assert that the sale price and markup percentage were as follows: Sale Price Markup Percentage Compact discs $11.99 15% Cassettes 7.99 15% Cassette singles 2.49 25% Records 4.99 25% Overall average 20% In support of this, petitioners point to Mr. Ginsburg's testimony regarding the typical sale price of music products. He stated that the typical list prices for "release products on sale" were: Compact discs $11.99/12.99 Cassettes $7.98/8.98 In evaluating petitioners' conclusion that the overall markup percentage is 20 percent, we begin with their asserted sale price. Petitioners attempted to establish their sale price by Mr. Ginsburg's testimony regarding the typical price for release products on sale, and by receipts from Target, Blockbuster Music, and Circuit City. However, Mr. Ginsburg stated he had no knowledge of what petitioners were actually selling their products for, and petitioners presented no evidence regarding the prices they sold the products for. We are not persuaded of the accuracy of petitioners' stated sale prices. WePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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