Bausch & Lomb Incorporated and Consolidated Subsidiaries - Page 74

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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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