our first case is morning is paul miller versus the united states mr depressed a sales only in the limited sense that they have to buy the batteries before they can sell them but that does not make it a selling expense and in addition we don't have to just throw out on what the statute says if you perhaps think that the statute is not clear from what the statute had in mind the statute had in mind of making a comparison between two prices as contemporaneous as possible in the home market price and the us price and have the conversion of the home market price in this case done  using the date of sale using the conversion that is and in fact on the date of sale of the us now if you're going to modify your expense calculation based on the transaction transaction between the two quickly on the second issue the second issue had to do with the calculation of inventory carrying cost as i said and this one thing that i thought i would like to get out of the way for from the get go on that issue there's going to be a lot definitions that are being used and have been used to tear their cases to the final dumping or not to cripple trolling sections of the ne duffy law on how to calculate any dumping margins and how to calculate the amount of  must be paid in response to a review of the calculations are made under very specified specific guidelines and provisions in the statute on how to calculate normal value and then on that point they would just suggest that there has been a change that this just might fall we three and a half years ago for this appeal there have been dug into your decisions which the commerce department and the u s trade representative have followed and there are applying the determinations from those those panels and so we would suggest that at this point change has been made since the s k case and that the courts could take different could could just consideration of what the government is actually doing with regard to zeroing in these proceedings as well as having the right to review this statute again this panel to review the statute under the proper criteria that we submit is a chevron one and so we would suggest at this point the time has  because this is the this is the expense it's occurred in the united states is not directly not directly related to any particular sale and united states but it is most certainly related at least in part to the sales i united states the value we're trying to find out what do conversion rates have to do with that what the sales price is an asset to the proper adjustment to the asset of the pool of indirect selling but how could this be an expense it's an os that took all of expenses and more it's a more proper adjustment because there is a because in the during the purchase of the acquisition of the bearings by the affiliate the affiliate purchases the bearings and there happens it's a matter of the way this selling operation operates its business the united states it purchases the bearing from the parents in germany and euros there's a passage of time for renewal rates after the act is that there's a long process let me ask you a question is not this is not a result oriented certainly from a perspective a department congress is not a result oriented it was alternative calculation it's simply a way to make it more accurate adjustment of the regular general operating general ministry you we based our judgment on following commerces policy and we're deferring under several under your policy which policy do we follow the one complex very specific statutory scheme congress is implementing adverse w t f decisions it is made a determination as to is there in practice with regard to investigations that has not made a determination with regard to misread reviews implement that as that is limited to investigations this is this this court and s k has upheld the practice with it as a matter of domestic law and the statement ministration clearly statement of industry that actually clearly contemplated that notwithstanding what might happen after an adverse w t o decision not withstanding what may happen after implementation of a decision as a matter of domestic law whatever thomas it previously  is is reasonable appropriate as a matter of domestic law and that statement ministration straight action clearly contemplates that there will be this disparity i mean that's that's the statute that's the scheme that's just the way the system works and it is for the political branches to decide and as this court has repeatedly held unless and until there's a change and implementation this court is going to uphold congress's interpretation of the statute is reasonable and quite as any for the questions if i could just as a couple of the questions that the court has posed to my colleagues this morning one question was what does the currency conversion have to do with us price or home market price in short not that we are not determining what the starting price is in computing the dumping margins what we are determining here with respect to form currency exchange again issue is what is jim and bearing us is overhead what are actual right expenses and how should that be deducted from the start of us price which is not a question in computing the dumping margin here as congress is well established practice is to consider positive expenses and negative expenses or offsets which is what we have here this is not a revolutionary practice it's a well tried ground and tim can seems to and prevents recognizing offsets altogether which obviously is not a credible reading statute so secondly is while yes form of currency exchange is related loosely communications back and forth between the parent and the u s we said company and i don't think anybody would take the position that those sales are not but those expenses are not overhead items that should be recognized in stock to follow us to the u s starting price i think that's all to three fifty one for it to be prevents the recognition of expenses that are realized between the u s and the affiliate in the form of foot and they rely upon that statute in order to try to deny the foreign currency exchange again recognized by same and the turnover rate in inventory is the same you would have exactly the same into thirty cost calculated for the us in the home market which is absurd because the product that is made in the home market has to be brought over here if it if you look at that