- 78 - Moreover, in calculating the markup taking into account respondent's increase in gross receipts, Shimmon accepted as accurate the reductions to purchases expense determined by respondent on audit. Following concessions by the parties and our decision relating to that issue, see supra, Shimmon's figures are no longer accurate. Rather, after taking into consideration the adjustments to the unreported income and cost of goods sold determined by respondent as discussed supra, the restaurants' markups for the years in issue fall below the 225-percent top range used by Shimmon.18 Consequently, the adjusted purchases 18 Using totals for the two restaurants owned by Toraya and the one restaurant owned by the Takaos, the adjusted markups are computed as follows: 1988 1989 1990 1991 Gross receipts per return $1,286,571 $997,067 $810,958 $740,860 Unreported income 90,900 78,675 35,400 7,800 Adjusted gross receipts 1,377,471 1,075,742 846,358 748,660 Cost of goods sold per return 467,757 357,634 279,183 249,129 Adjustment to purchases (3,000) (3,100) 6,000 -- Adjusted cost of goods sold 464,757 354,534 285,183 249,129 (continued...)Page: Previous 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 Next
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