Chong-Kak and Sang-Ok Lee - Page 10

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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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