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v. USDA, supra. The marketing of tobacco in excess of a
producer's allotment, so-called excess-quota tobacco, is
subject to a penalty. See id.
In the notices of deficiency issued to petitioners,
respondent made two principal adjustments to Beaufort
Leaf's returns for 1990 and 1991. First, respondent
increased the gross sales reported by the partnership.
The explanation of that adjustment in the subject notices
of deficiency is as follows:
It is determined that the partnership had
additional income from tobacco sales for tax
years 1990 and 1991 that was not reported on
the returns. It has been determined that
tobacco sales totaled $2,153,228.00 in 1990
and $3,904,027.00 in 1991 instead of the amounts
of $1,264,700.00 and $2,849,451.00 as shown on
the returns. Accordingly, the partnership net
income is increased $888,528.00 in 1990 and
$1,054,576.00 in 1991. (See attached.)
The attachment referred to in the above explanation
states that Beaufort Leaf's tobacco sales for 1990 were
recomputed as follows:
(1) Sales of flue-cured tobacco $1,225,535
(2) Sales of burley tobacco 853,015
(3) Sales of tobacco "not in the form" 74,678
TOTAL TOBACCO SALES FOR 1990 2,153,228
Claimed on return 1,264,700
Net adjustment to gross income 888,528
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