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tioners within the meaning of section 957(a), and B&L Ireland and
B&L Hong Kong maintained their books and records on the accrual
method of accounting using a 52-53 week taxable year.
B&L Inc. and Subsidiaries8
B&L traces its roots to an optical shop located in Rochester
that was founded in 1853 by John J. Bausch and Henry Lomb. Prior
to World War I, B&L became the first producer in the United
States of optical quality glass, a vital material for military
instruments, that freed the United States from its dependence on
European sources of such glass.
Prior to and during the years at issue, B&L manufactured and
sold a wide range of optical-related products, including contact
lenses, contact lens solutions, sunglasses,9 binoculars, tele-
scopes, and scientific instruments (e.g., microscopes).10 Prior
to the years at issue, B&L manufactured and sold prescription
eyeglasses. Prescription eyeglasses are a separate and distinct
product from noncorrective sunglasses. Prescription eyeglasses
contain individually finished, corrective lenses, are tailored
8 Hereinafter, we shall refer to B&L Inc. and all of its sub-
sidiaries, not just those subsidiaries that were consolidated for
Federal income tax purposes, as B&L.
9 As used herein, the term "sunglasses" means sunglasses with
noncorrective lenses.
10 B&L was also involved in certain biomedical fields. However,
that segment of its business is not relevant to the issues
presented in these cases.
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