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Table 5 shows diesel fuel sales net of diesel fuel excise
and sale taxes, as set forth on the PLS’s for January, February,
April, May, and June 1990--the only PLS’s introduced as evidence.
Table 5
Month Diesel Fuel Sales
January 1990 $327,035
February 1990 313,935
April 1990 290,546
May 1990 292,159
June 1990 311,840
Total 1,535,515
On petitioner’s fiscal 1990 tax return it reported gross
receipts, cost of goods sold, and gross profit in gross; i.e.,
not broken down according to the different activities carried on
at its truck stop. The amounts so reported match the “year to
date” amounts on the last PLS, which show the separate results
for each activity. Table 6 shows selected information from the
last PLS and shows the percentages for diesel fuel.
Table 6
Diesel Fuel As
Category Totals Diesel Fuel Percent of Total
(1) Income $4,152,428 $3,340,825 80.5
(Gross receipts)
(2) Cost of sales 3,463,255 2,959,767 85.5
Gross Profit 689,173 381,058 55.3
((1) minus (2))
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