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service prices, to reconstruct petitioner’s diesel fuel gross
receipts. The numbers in Lundberg’s report and in the
reconstruction of petitioner’s income match respondent’s agent’s
testimony. Our understanding of what was done in respondent’s
reconstruction of petitioner’s income on this point matches
respondent’s agent’s testimony. Petitioner apparently has
completely misunderstood the record on this point, much as it
misunderstood the record regarding the reconstruction of the
number of gallons of diesel fuel that it sold, discussed supra.
Thus, every part of petitioner’s expressed concern is either
flatly contradicted by the record or (contrary to petitioner’s
assertion) not addressed in the record; the record does not
support any part of petitioner’s expressed concern.
In light of the record herein we conclude that respondent’s
reconstruction, as we have slightly modified it, is the best that
can be done to determine the prices at which petitioner sold
diesel fuel during petitioner’s fiscal 1990.
(c) Cost of Goods Sold. Respondent has explained the
reconstruction of petitioner’s cost of goods sold with regard to
diesel fuel as the product of (1) the number of gallons
petitioner bought in petitioner’s fiscal 1990--an amount equal to
the number of gallons petitioner sold that year, and (2) the
average price per gallon that petitioner paid--an amount equal to
the average cost shown on petitioner’s incomplete purchase
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