Estimated profit rate for business income after income reclassified as business-6% kept as past-consistent; 10% increase overturned.

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....Estimation of profit margin for income reclassified as business income must be based on reasonable, consistent historic results and identifiable comparables; where the taxpayer's 6% profit rate matched prior accepted assessments and no abnormal features, benchmarking, or specific comparables justified an upward revision, the higher 10% estimate was unsustainable and the 6% rate was to be applied, resulting in allowance of the appeal.....