- 80 -
with the least damage to the parts occurring during the process.
See Webb Export Corp. v. Commissioner, 91 T.C. at 143. The
record in these cases shows that it took significant periods of
training and experience for operators to learn the standardized
techniques utilized by B&L Ireland and by B&L Hong Kong to as-
semble sunglasses ready for sale to the ultimate consumers. Even
Dr. Cohen admitted that certain problems encountered by B&L
Ireland and by B&L Hong Kong might have been attributable to the
fact that they were mass producing sunglasses, rather than assem-
bling prescription eyeglasses for a retail optical shop.
In addition, the sunglasses assembled at both B&L Ireland
and B&L Hong Kong were inspected at least once by someone other
than the operator who assembled them to ensure that the sunglas-
ses complied with B&L's quality standards. Dr. Cohen testified
that, at least in Ohio, an optician was required to examine
prescription eyeglasses before they were distributed to the
ultimate consumer. Although the position of an inspector at B&L
Ireland and at B&L Hong Kong was not the equivalent of an
optician who is licensed and trained to dispense prescription
eyeglasses, the record in these cases establishes that inspectors
at B&L Ireland and at B&L Hong Kong required significant periods
of training and experience in order to perform their jobs proper-
ly. The need for trained inspectors to ensure that the sun-
glasses assembled by B&L Ireland and by B&L Hong Kong met B&L's
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