Chong-Kak and Sang-Ok Lee - Page 11

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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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