Nick and Helen Kikalos - Page 15

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          however, and not of the Commissioner.  Mendelson v. Commissioner,           
          supra at 523.                                                               
          II.  Respondent's Use of the Percentage Markup Method                       
               We must find petitioners' gross profit for each of the years           
          at issue.  Their gross profit is the difference between the price           
          at which petitioners sold their inventory and their cost of                 
          purchasing that inventory.  Gross profit may be expressed in                
          terms of dollars, but gross profit is also often expressed in               
          terms of percentages--either "margin" or markup".  "Margin"                 
          refers to gross profit as a percentage of the price at which                
          petitioners sold their inventory.  "Markup" refers to gross                 
          profit as a percentage of the cost incurred by petitioners to               
          purchase that inventory.  Margin and markup are related terms,              
          and, if we know a specific example of one, we can determine the             
          other.  For example, a gross profit margin of 20 percent means              
          that the markup is 25 percent and vice versa.                               
               In this case, respondent employed the "percentage markup"              
          method to determine that petitioners had underreported their                
          income.  In the proceeding before us, however, each side has                
          attempted to prove its case by demonstrating the profit margins             
          at which petitioners, or other retailers, sold their merchandise.           
          Because the parties have made their arguments in terms of profit            
          margins, we shall use that approach as well.                                
               Here, because of petitioners' failure to retain records of             






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