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sunglass assembly operations of B&L Ireland involved approxi-
mately 75 steps in order to assemble plastics. Even petitioners
do not argue that the respective assembly operations of B&L
Ireland and B&L Hong Kong involved that many steps. We did not
find Mr. Matthews' opinions to be helpful in resolving the issues
in these cases, and we do not rely on them in making our findings
and reaching our conclusions herein.
Respondent relies on the opinions of Michael L. Philpott,
Ph.D. (Dr. Philpott), a manufacturing engineer, who, as of the
time of the trial herein, was employed as an assistant professor
of engineering responsible for teaching classes in manufacturing.
Dr. Philpott had no experience in the sunglass industry. His
opinions were formulated from the perspective of an engineer and
set forth certain hypertechnical views that we do not believe
Congress had in mind when it enacted section 954(d)(1) and that
we did not find helpful to our resolution of the issues herein.
By way of illustration, Dr. Philpott drew subtle distinctions
among the terms "manufacture", "manufacturer", and "manufactu-
ring". As discussed below, we do not believe Congress had any
such distinctions in mind when it made section 954(d)(1) part of
the Code.
To illustrate further our concerns with the opinions of
Dr.Philpott, he utilized a definition of the term "manufacturer"
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