- -17
surcharge fee charged by the Customs Service of $3 per shipment,
for a total of $196,721.15.
For documented sales, we allow petitioner freight charges as
shown on the matched customs invoices and as determined by
respondent. For those sales that are not documented, we hold
that petitioner is entitled to both the $65 customs entry service
fee and the $3 formal surcharge fee charged by the Customs
Service. There is no evidence for us to conclude, as petitioner
contends, that the freight charges for the one shipment in 1990
upon which petitioner relies should be the basis for imputing
freight charges to the shipments for the years before us. This
is particularly evident in light of the variation in the
percentage of freight charges for those purchases that can be
matched with the appropriate customs invoices. The following is
a list of those purchase invoices and customs invoices that
respondent could match and the corresponding percentage of
freight charges, including all fees:7
7 This table does not include invoices dated June 23, 1988,
and Sept. 19, 1988, because the freight charges on these invoices
were well outside the normal range (15.49% and .09%). These are
the same invoices mentioned supra note 6.
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