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the shipment was by sea, the shipper would send the shipping
documents to petitioner, and petitioner would provide these
documents to Alexander Air. Alexander Air then determined the
applicable U.S. customs duty rate for each item listed on each of
the shipping documents based on the rates shown in the Harmonized
Tariff Schedule of the United States, promulgated by the U.S.
International Trade Commission (the Harmonized Tariff Schedule).
Mr. Lee determined the amount of customs duty by applying the
rate specified in the Harmonized Tariff Schedule for a specific
classification of product to the various items listed on
petitioner's purchase invoices for the years at issue.
The U.S. Customs Service (the Customs Service) inspected
petitioner's documents and shipments infrequently during the
years at issue. None of the few Customs Service inspections made
of petitioner's goods and documents during the years here in
issue resulted in changes in the amounts computed by Mr. Lee.
Customs duty rates applicable to imported items depend on
such variables as the type of fabric (e.g., knit versus woven),
the use of the garment (e.g., undergarment versus outergarment),
the country of origin, and the fabric composition (e.g., manmade
fiber versus all cotton versus cotton-polyester blend).
The freight charge made by Alexander Air for shipment of
goods to petitioner was based on volume, expressed in cubic
meters.
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