Apollo Overseas International, Inc. - Page 19

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          this record other than a percent of value on which to estimate              
          the freight charges.                                                        
               For the fiscal year 1990, there are no customs invoices from           
          Alexander Air that match purchase invoices to determine the                 
          appropriate customs duties for either garments or badges.  There            
          are only purchase invoices for that year.  For 1990, respondent             
          has applied to each garment imported the lowest effective duty              
          rate that respondent calculated from 1989 that applied to the               
          same type item.  For freight and import charges, respondent                 
          applied a ratio of 1.99 percent.  Respondent allowed no amount              
          for customs duties for badges for petitioner's fiscal year 1990.            
          Petitioner applied the same method for each category of items for           
          its fiscal year 1990 that it applied for its fiscal year 1989.              
          The record suggests that customs duties and freight charges were            
          the same for the same item for petitioner's fiscal year 1990 as             
          for its fiscal year 1989.  We, therefore, conclude that the                 
          percentages for petitioner's fiscal year 1990 would not be                  
          substantially different from those for its fiscal year 1989.  We            
          hold that petitioner is entitled to a 17-percent customs duty               
          charge for all garments and a 4-percent customs duty charge for             
          badges for its fiscal year 1990.  We hold that petitioner's                 
          freight charges fees for its fiscal year 1990 were the same as              
          for its fiscal year 1989, and that its freight charges for its              
          fiscal year 1990 were 2 percent of the total purchase price,                
          which is the same as for its fiscal year 1989.                              




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