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section 954(d)(1) and the regulations thereunder. Except as
stated below, we did not find those opinions to be helpful in
resolving the issues in these cases. We did not find it neces-
sary or appropriate to rely on questionable, quantitative
analyses of the respective assembly operations conducted by B&L
Ireland and B&L Hong Kong in order to resolve whether those
operations satisfy the facts and circumstances test of section
1.954-3(a)(4)(iii), Income Tax Regs. Except as noted below, we
do not rely on the opinions of either Mr. Holdren or the three
individuals who prepared the BVS report in making our findings
and reaching our conclusions herein.
To rebut the respective opinions expressed by Dr. Philpott
and the three individuals who prepared the BVS report, petition-
ers rely on the opinion of Dr. Plotkin, an economist employed by
Arthur D. Little, Inc. While we found that Dr. Plotkin effec-
tively rebutted those opinions, we generally do not rely on his
opinions because they were provided to rebut the opinions of
experts upon whom we generally do not rely.
All of the experts who prepared opening reports, except Dr.
Cohen, prepared rebuttal reports expressing opinions intended to
refute the opinions expressed in the opening reports of one or
more of the experts relied upon by the other party. Except for
Mr. Nieh's rebuttal of Dr. Cohen that we found to be helpful in
explaining the differences between the assembly of sunglasses and
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