Turnover suppression estimate must rest on year-wide material; inspection-day sales alone cannot justify full-year addition.

An estimate of suppressed turnover based mainly on sales noticed on a single inspection day cannot be extended to the full assessment year without a reasonable nexus to material showing year-long suppression; the court therefore reduced the addition in part. Additions sustained on other items were maintained because no legal infirmity was shown in those findings, and the consequential penalty was upheld proportionately to the turnovers retained.

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Issues: Whether the addition to turnover based on the inspection-day sales and the consequential penalty could be sustained for the whole assessment year.

Analysis: The assessment rested substantially on the sales noticed on a single day, with no other strong material showing pervasive suppression throughout the year. An estimate for the full year must have a reasonable basis and a nexus with the materials found; where the only defect is the absence of certain supporting records and the possibility of fluctuations in sales remains, a wholesale adoption of the assessing officer's estimate is not justified. The turnover already sustained for other items was not shown to suffer from any legal infirmity. The penalty was consequential to the turnovers upheld.

Conclusion: The estimate of suppression was reduced in part, while the additions sustained on other items were maintained. The consequential penalty was upheld proportionately.

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