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Some of the facts have been stipulated and are so found.6
Bausch & Lomb Incorporated (B&L Inc.) is a corporation
organized under the laws of the State of New York. At the time
the petitions were filed, its principal corporate offices were
located in Rochester, New York (Rochester). B&L Inc. and certain
of its subsidiaries filed consolidated Federal income tax returns
(Forms 1120) for the taxable years ended December 25, 1983,
December 30, 1984, December 29, 1985, December 28, 1986, and
December 27, 1987.
For each of the years at issue,7 petitioners kept their
books and records and filed their Federal income tax returns on
the accrual method of accounting using a 52-53 week taxable year.
B&L Inc. was a U.S. shareholder of B&L Ireland and of B&L Hong
Kong within the meaning of section 951(b), B&L Ireland and B&L
Hong Kong were controlled foreign corporations (CFCs) of peti-
5(...continued)
placed on the briefs in these cases, we shall impose no sanctions
at this time. However, we caution petitioners and their counsel
that any further violations of our Rules and Orders will be met
with the imposition of appropriate sanctions, regardless whether
respondent makes a request for sanctions.
6 Each party objected to certain stipulations in the first
stipulation, the second stipulation of facts, and the third
stipulation of facts. (Those stipulations will be referred to
collectively as the stipulations of facts.) We address those
objections below.
7 Unless otherwise indicated, our Findings of Fact and Opinion
herein relate to the years at issue.
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