here or partner part of this policy now that standing to decisions of this court interpreted the statute to require including such that in cd unless renewed or refunded upon exportation in this case the recorded  if they were imported and import duties in the sociedad vat were suspended and funded in the brazilian drawback system based on exploitation of the finished product there is no evidence in this case that we may use this system to is why don't the question area it's yours which were the subject of some audit provide substantial evidence to support the conclusions reached and why is your objection specific discrepancies with respect to electors and ask congress to verify it to examine it and they didn't examine that issue at all over the case in the only examined what the needed to examine do apply he interpretation or the language itself well there but the credits are equivalent to cash in effect they can be used to purchase imports not simply to offset o it's actually very similar the two mechanisms it but they have an obligation to pay taxes in brazil they're not mission pay for their you know their influence it's there they're using in a what with these other types of mechanisms that tactic of certainly doesn't exist and you know at the end of the day if the language of the statute is clear that that's the end of the matter we in our view congress reasonably can could decide that that this is the only circumstance where there is this direct nexus that that tax would be excluded from constructed out of commerce is trying to go beyond what congress provided for and that's that's just commerce essentially includes all costs connected with producing merchandise including taxes and tries as best as possible to determine as accurately as possible the actual cost incurred by a company whether it's for a material import such as charcoal or electricity or if it's some cost that's not it's otherwise not tangible such as taxes or interest or those kinds of upon exploitation as is the case with the brazilian value added taxes that commerce may accurately account for the amount of taxes actually occur in producing the merchandise the so you arguing that the statute while specifying when the taxes must be excluded doesn't specify when the taxes must be in it does not specify the tax must be included  presumably they should be included if they aren't part of producing the merchandise they should be executed under the statute as a matter of law if they were limited or we funded a coin exportation otherwise they need to be considered in the calculation for determining constructor value so you do them and i think this set off entirely i'm sorry i didn't hear your entire thing you said then your you eliminated the set often and just require that it be of the words statute otherwise they get the taxes paid exists as a potential cost just as the cars for any other aspect of producing the merchandise and so determining accurately as possible the amount of taxes actually incur is what congress tries to do if they are offset will recover in some manner then congress will recognize that offset or recovery that was what i was a me and that is what the trial court in this case precluded commerce from doing the trucker in this case it because they never made it a refund upon exportation in congress cannot recognize any offset or recovery and accurately determine the amount of appealed because they say they would like congress to impute some tax amount with regard to electrodes in this matter the only evidence on the record with regard to that or the verified questionnaire responses from way which gives an amount of value to taxes paid for the electorate that's the amount that congress ultimately decided was the correct amount to be used in that there was no basis for actually computing some congress methodology and allow congress to accurately account for taxes and to deny outcomes appeal since there is no evidence to support the imputation that they would like congress to make mr stevens argued that some questions were raised as to the accuracy of the questionnaire responses and and commerces audited results and suggested that under those circumstances commerce an obligation to go back location of the producer in this case in brazil and examines there and some of the matters that are going to be examined are announced to the company in advance so that the company can prepare for that and make sure it has all of the appropriate records available for commerce to examine some of the issues commerce made salmon are not according to the company until congress is actually there and so there is somewhat of a surprise to the company congress does in this court has recognized to prove the fact that congress does not actually conduct a full blown full scale audit examining every single piece of paper connected with the courtroom sponsons in this case questionnaire responses it is true as mr stevens pointed out this was simply commerce did not look at this precise issue with regard to the electorate but determining that because it verified many this questionnaire responses and found no significant discrepancies that it was appropriate to accept as accurate all of whom is questionnaire responses and even in the page with questions raised with regard to the the decision in elk and warm the court of international trade made the statement that quote when internal taxes are not refunded or remitted on exportation of the subject merchandise go decision but that's not what the statute says that's right what the statute says that constructed valuable in the cost of materials  statute that's what you can read the statute that way certainly but you can also read the statute is being open ended leaving commerce with the flexibility to make its assessment of constructive value based on all of the factors that