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Originally Posted by Mr. Kite
The dealer would have filled up the tank just before you took delivery, but they may not have reset the trip odometer. Another thing that could cause an error is a difference in fillups. The dealer could have topped off and you may have stopped at the first click. Both of these scenarios would inflate your mpg for a tank.
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Those factors would influence his calculated FE, but not the FE computed by the trip computer.