Andy Rataiczak - Page 6




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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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