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assets between $0 and $500,000. Petitioner estimated that he
charged an average markup of between 7 and 8 percent in the sale
of tires and other parts. However, the documentary evidence in
the record does not support this estimate.
The parties stipulated as evidence six invoices from
petitioner’s service station written in 1993; however, there is
evidence with respect to the applicable wholesale cost with
respect to only two of these invoices. One of the invoices, to
Anco, dated January 22, 1993, shows that petitioner charged $105
for tires. Petitioner contends that the wholesale cost for these
tires at the time of sale was approximately $100, for a markup of
approximately 5 percent. Respondent contends that the wholesale
cost was $95 and concedes that the markup on tires was no more
than 10 to 10.5 percent. Petitioner’s cost of labor was included
in the retail price of the tires. The other invoice, also to
Anco, dated August 21, 1993, shows that petitioner charged
$152.35 for a power steering pump, and that he charged an
additional $30 for labor to install the pump. Respondent
contends that the wholesale cost of the pump was $133.80 at the
time of trial, based on a phone call to a local wholesaler.
Using the cost at the time of trial, the markup that petitioner
charged Anco for the power steering pump was $48.55 ($152.35 +
$30 labor - $133.80 current cost), or 36.3 percent ($48.55 �
$133.80). If the time-of-trial wholesale price were adjusted for
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