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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 not
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