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be vague and uncertain and not sufficient to rebut
respondent's determination.
Second, we reject petitioner's argument that his gross
receipts should be reduced by additional expenditures not
reflected in respondent's calculation. These expenditures
consist of various fees allegedly paid to individuals
involved in the drug smuggling operation, including
individuals responsible for unloading the boat after it
arrived in New Jersey and the owner of the dock where the
boat was unloaded, and amounts allegedly paid to satisfy
debts from previous drug transactions. In passing, we
note that in his calculation of net profit set out above,
petitioner deducts $550,000 as an amount paid to satisfy a
debt arising from the Hot Tubs case. However, petitioner
testified during his plea hearing in the criminal case that
he paid only $250,000.
Section 280E provides that no deduction or credit
shall be allowed for any expenditure paid or incurred in
carrying on a trade or business which consists of
trafficking in controlled substances. See sec. 280E;
S. Rept. 97-494, at 309 (1982). Marijuana is a controlled
substance as defined in section 280E. See Browning v.
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