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Finally, respondent reduced petitioner's gross
receipts by the cost of petitioner's share of the
marijuana. Respondent computed the cost of goods sold by
first determining that petitioner and his coconspirators
had paid $16 per pound to purchase the marijuana from the
Colombian wholesalers. Respondent derived this amount from
information provided by the Drug Enforcement Administration
regarding the average wholesale price of Colombian
marijuana during the period in question. Respondent next
increased the wholesale price of the marijuana by $11.36
per pound. This is the amount that petitioner and his co-
conspirators had paid to Mr. Cabeceiras, the boat captain,
for transporting approximately 44,000 pounds of marijuana
from South America to New Jersey ($500,000 � 44,000 pounds
= $11.36 per pound). The record does not explain why
respondent allocated the boat captain's fee to 44,000
pounds of marijuana. In any event, respondent determined
that the sum of these amounts, $27.36, is the total cost
of goods sold, computed on a per-pound basis. Respondent
determined that the cost of the marijuana sold by
petitioner is $342,000 (i.e., 12,500 pounds x $27.36).
Reducing petitioner's portion of the gross receipts by the
cost of goods attributable to his portion of the marijuana,
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