' functions, the objections stated may not be valid, but any
importers' costs of reselling to jobbers should undoubtedly have been
collected and considered.

It may further be noted that some American manufacturers actually sell
their hats to retailers. Such domestic selling expenses were secured by
the commission on its schedules, and there is reason to believe that
certain overhead items in the assembled costs are probably larger than
they would otherwise be because of the imperfect allocation of selling
and manufacturing expenses.

_Deficiencies in comparative overhead data._--More striking in some
respects than the failure to secure importers' selling expenses is the
contrast exhibited in the commission's report between overhead expenses
in the United States and abroad. The foreign overhead expenses are mere
estimates, since the commission's representatives were refused access
to the original books and records by practically every foreign firm.
It accordingly became necessary to resort to estimates based on flat
percentages of prime costs or sales price. These were in fact submitted
by Italian manufacturers and used by the commission's representatives.
It now develops that these percentages have never been analyzed or
justified. Indeed, there is no definite record of what expense items
were included or neglected in such percentages. The overhead expenses
in the United States include very considerable salaries paid to officers
of the domestic manufacturing concerns, and the question is presented
whether, as some accountants maintain, such salaries should not be
charged exclusively to selling rather than manufacturing expenses, since
such officers usually pay more attention to the selling end of the
business. In the commission's records it appears that about 85 per cent
of the total officers' salaries was charged to manufacturing and about
15 per cent to selling. The importance in cost investigations of
scrutinizing high salaries should be evident, as they might easily be,
although, in this instance it is not suggested that they have been, used
to conceal profits. It is worthy of note that the average salaries
allowed by the commission's representatives in the domestic costs of all
the hats manufactured amounted to 69 cents per dozen--nearly as much as
the entire average Italian overhead charge. It is to be remembered, as
already stated, that this average amount does not include the additional
item allowed in the sel