Bausch & Lomb Incorporated and Consolidated Subsidiaries - Page 54

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          for distribution in the United States.  Nor did either company              
          sell sunglass parts to retailers except as replacements for                 
          repair work.  Neither B&L Inc., B&L Ireland, B&L Hong Kong, nor             
          anyone else in the sunglass industry sold sunglass parts to the             
          ultimate consumer.                                                          
          Tax Return Treatment                                                        
               For each year at issue, petitioners reported none of the               
          income of B&L Ireland and of B&L Hong Kong from the sale of                 
          sunglasses they assembled as income under subpart F of the Code             
          (subpart F).                                                                
               For each of their taxable years ended December 30, 1984,               
          December 29, 1985, and December 28, 1986, petitioners reported              
          certain of B&L Hong Kong's income from sources other than the               
          sale of sunglasses assembled by it as subpart F income.30  Petit-           
          ioners did not report any of B&L Hong Kong's income as subpart F            
          income for its taxable year ended December 25, 1983.  A memoran-            
          dum prepared by B&L in connection with the tax audit of petition-           
          ers' taxable years ended December 25, 1983, and December 30,                
          1984, indicated that petitioners did not report any of B&L Hong             
          Kong's income as subpart F income for their taxable year ended              
          December 25, 1983, because that company "generated an overall               
          loss from subpart F operations" for that year.                              


          30  It is not clear from the record what all of the sources of              
          B&L Hong Kong's reported subpart F income were for those years.             




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