Apollo Overseas International, Inc. - Page 16

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          customs duties.  Based on the evidence, we conclude that                    
          petitioner's method of determining customs duties for badges                
          yields too high an amount.  The Harmonized Tariff Schedule showed           
          percentages for customs duties for badges that were substantially           
          lower than percentages for garment sales.  Based on the limited             
          evidence before us, we conclude that petitioner is entitled to a            
          4-percent customs duty for badges in 1989.                                  
               Respondent has allowed freight charges for petitioner's                
          fiscal year 1989 as shown for those shipments on invoices that              
          can be properly matched.  For the invoices that cannot be                   
          matched, respondent has credited petitioner with freight charges            
          of only the $65 entry service fee, on the basis that the other              
          fees and charges varied widely.                                             
               Petitioner contends that a much higher amount for freight              
          charges is appropriate.  Relying on an invoice from a later year,           
          petitioner contends that freight charges should equal 5.4 percent           
          of the value of the shipments for the years here in issue.                  
          Petitioner argues that total freight charges allowed for the                
          fiscal year 1989 should be $184,322.41.  In addition, petitioner            
          maintains that it should be allowed to claim a formal entry fee             
          of $65 per shipment as part of cost of goods sold, as well as a             
          merchandise processing fee charged by the Customs Service in the            
          amount of .17 percent of the value of the merchandise.  Finally,            
          petitioner contends that it should be allowed to claim the formal           






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