- 10 - attributable to these sales. At trial, respondent supported her determination with the testimony of two experts who concluded that Hamalee's gross profit percentage could be as high as 24.9 percent. In reaching their conclusions, respondent's experts considered various factors (e.g., economic, investment market, and industry conditions) related to the selling of beer during the relevant time frame. Respondent's experts also reviewed Hamalee's sales and purchases journals, as well as its tax returns, and referred to several relevant financial publications. Petitioners argue that Hamalee's gross profit percentages were 9.7568 percent, 8.9763 percent, 7.9707 percent, and 7.612 percent for its 1985 through 1988 taxable years, respectively. At trial, petitioners presented an "expert" to attempt to disprove respondent's determination and to support their claim to the lower gross profit percentages. Petitioners' "expert", Stan Lee, concluded that Hamalee's gross profit percentages equalled the percentages claimed by petitioners. In reaching his conclusions, Stan Lee reviewed some of Hamalee's purchases and sales documents, and he assumed that this sample was representative of all of Hamalee's purchases and sales documents. Stan Lee did notPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011