Chong-Kak and Sang-Ok Lee - Page 12

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          Petitioners argue that Stan Lee used this "better data" and                 
          computed Hamalee's gross profit percentages at the amounts that             
          petitioners ask us to find.  We are unpersuaded.  In addition to            
          the fact that petitioners have failed to convince us that                   
          respondent's method of computation was less accurate than                   
          petitioners' "better method", we bear in mind that Hamalee's cash           
          sales accounted for a large portion of its total sales and that             
          most of Hamalee's cash sale invoices were destroyed.  Thus, even            
          if we were to agree with petitioners that the use of Hamalee's              
          actual data was the better method for computing its gross profit            
          percentages, we could not have applied the "better method" in the           
          case at hand because the record contains insufficient data.                 
               We also were not impressed with the presentation of Stan               
          Lee, and we view most of his conclusions to be unpersuasive.                
          His testimony and report lacked coherence, and they were not                
          helpful to the Court.  His conclusions were partially based on              
          Hamalee's sales invoices, which did not include the ones that               
          were destroyed, and he reviewed only a fraction of the already              
          incomplete records to arrive at his conclusions.  We need not               
          follow an expert's conclusions that are contrary to our better              
          judgment, see, e.g., Helvering v. National Grocery Co., 304 U.S.            

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