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review all of Hamalee's purchases and sales documents, and he did
not consider any extrinsic evidence.
We agree with respondent's determination of Hamalee's gross
profit percentages. We found her experts to be credible, and
we found their presentations to be methodical, empirical, and
persuasive. Respondent's lead expert, the president of a
valuation company headquartered in New York, New York, has given
expert testimony on fair market valuation and financial analysis
for over 30 years in this and other Courts. He is a graduate of
Princeton University, Phi Beta Kappa (junior year), Magna Cum
Laude, and Lyman Biddle Senior Scholar. He has authored numerous
books and articles, and he is a member of numerous professional
associations, many of which he has chaired. In addition to the
weight that we give the testimony of respondent's experts, we
also find relevant the fact that respondent conservatively
determined Hamalee's gross profit percentage at 12 percent for
each year, although her experts testified that the percentages
could be as high as 24.9 percent.
Petitioners argue that respondent's determination is
erroneous because it is based on industry standards rather than
the "better data" of Hamalee's actual purchases and sales.
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