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respondent determined that petitioner realized $3,158,000
from the transaction.
Petitioner does not dispute certain factual
assumptions made by respondent in calculating the gross
receipts from the Michigan transaction. In fact,
petitioner agrees that a total of 25,000 pounds of
marijuana was sold to Mr. Erickson for an average price
of $280 per pound. Petitioner argues that respondent made
three errors in computing petitioner's income. First,
petitioner argues that he and his coconspirators paid $80
per pound to the Colombian wholesalers for the marijuana.
Second, petitioner maintains that his gross receipts from
the Michigan transaction should be reduced for expenditures
not reflected in respondent's calculation. Finally,
petitioner maintains that the proceeds of the transaction
were divided three ways, rather than two as determined by
respondent.
The following schedule compares petitioner's
computation of his net profit from the transaction with
respondent's:
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