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remaining 68 percent of the wine and liquor inventory.
Respondent does not contest the average December margin of 7
percent. Respondent does take issue with Dr. Rossi's conclusion,
based upon the checks written during December of 1991 and the
first week of January 1992, that 32 percent of annual wine and
liquor sales took place in December of 1991. Petitioners' ledger
books for their three stores indicate total December sales of
$934,920. Their 1991 tax return indicates total annual sales of
$9,054,086. Thus, their books and tax returns indicate that
approximately 10.32 percent of total sales of all products took
place in December. We conclude that, while December was a month
of heavier-than-average sales of wine and liquor, such sales did
not amount to 32 percent of the total.
Moreover, we question Dr. Rossi's assumption that the
overall margin on wine and liquor for the other 11 months of the
year averaged 14 percent. That percentage seems somewhat
arbitrary. Dr. Rossi apparently was not made aware that
petitioners' unadvertised sales of wine and liquor provided much
higher profit margins, such as 17 percent on a liter of Jack
Daniels whiskey, 26.1 percent on a 750-milliliter bottle of
Riunite Wine, and 22.8 percent for the same size bottle of Andre
Pink Champagne.
Our review of the record indicates, moreover, that the 7-
percent average margin applicable to advertised wine and liquor
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