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Taxable Income As
a Percentage of
Shareholder Equity
1999 2000
Petitioner 86.9% 52.6%
SIC code 5063 and 5065
companies:
High 49.9 49.5
90th Percentile 29.1 34.9
3d Quartile 21.6 23.6
Median 12.8 12.6
Mean 1.6 -46.7
He concluded from this calculation that approximately one-third
of the 34 companies lost money for their shareholders in each of
the analyzed years and that the return on equity produced by
petitioner in both subject years exceeded the maximum return of
any of the 34 companies.
As to the latter calculation, the ratio of gross profit to
sales (expressed as a percentage), Wertlieb calculated for
petitioner and each of the 34 companies the following
percentages:
Gross Profit As A
Percentage of Sales
1999 2000
Petitioner 49.3% 69.4%
SIC code 5063 and 5065
companies:
High 50.6 48.2
90th Percentile 31.5 34.5
Median 20.4 22.5
Mean 20.4 22.1
10th Percentile 8.6 9.0
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