William Henry Sundel - Page 16

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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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