Bausch & Lomb Incorporated and Consolidated Subsidiaries - Page 4

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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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