DHL Corporation and Subsidiaries - Page 63

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          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 compute              









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