- 148 - average markups ranging from a negative 6 percent to a positive 5.2 percent. The median percentage was 4 percent, the amount used for all years by respondent’s expert. Petitioners do not dispute the information that respondent’s expert derived directly from financial and business records but disagree with his estimation and extrapolation process to approximate or estimate the imbalance that existed in years for which no specific records were maintained by petitioners. In particular, petitioners contend that growth in outbound shipment volumes cannot be determined by means of the growth rate in annual revenues. Petitioners indicate that the relationship between DHL’s growth rates should not be used to gauge inbound shipment growth, which relates to DHLI’s business. This approach, petitioners argue, does not accurately estimate actual results. Petitioners also point out that respondent’s expert was selective in his use of projection material in that he used 1987 data to project 1979 through 1983 figure estimates, rather than the more contemporaneous information that was available from 1984 through 1986. Although the criticisms made by petitioners are numerous, petitioners have not offered a more accurate method of estimating the actual imbalances that existed during the years in question. Respondent’s expert attempted reasonably to computePage: Previous 138 139 140 141 142 143 144 145 146 147 148 149 150 151 152 153 154 155 156 157 Next
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