William Henry Sundel - Page 14

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             at 686-687; Bratulich v. Commissioner, T.C. Memo. 1990-600.              
             The Commissioner's reconstruction need only be reasonable                
             in light of all the surrounding facts and circumstances.                 
             See Petzoldt v. Commissioner, supra at 687; Giddio v.                    
             Commissioner, 54 T.C. 1530, 1533 (1970); Schroeder v.                    
             Commissioner, 40 T.C. 30, 33 (1963).                                     
                  Respondent calculated petitioner's unreported                       
             income on the basis of the amount of marijuana sold to                   
             Mr. Erickson, approximately 37,000 pounds.  Respondent                   
             deducted 5,000 pounds for wrapping and packaging material                
             and 7,000 pounds to allow for the marijuana that                         
             Mr. Erickson returned as wet and unusable.  Respondent,                  
             thus, determined that Mr. Erickson purchased a total of                  
             25,000 pounds of usable marijuana.                                       
                  Respondent found that petitioner and Mr. Lubiejewski                
             sold the marijuana to Mr. Erickson for approximately $280                
             per pound.  Based on a net weight of 25,000 pounds of                    
             marijuana sold, respondent calculated the gross receipts                 
             from the sale as $7 million.  Because these receipts were                
             split equally between petitioner and Mr. Lubiejewski,                    
             respondent determined that petitioner's gross receipts were              
             $3,500,000.                                                              








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