Bausch & Lomb Incorporated and Consolidated Subsidiaries - Page 88

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          companies (1) leased production facilities to assemble sunglasses           
          and warehouses to store finished goods; (2) employed management             
          teams to prepare production plans and order parts from their                
          suppliers; (3) hired and trained the necessary personnel to carry           
          out their operations; (4) inspected purchased parts for defects             
          and prepared those parts for assembly; (5) assembled sunglass               
          parts into finished sunglasses; (6) inspected finished sunglasses           
          for cosmetic and functional defects; and (7) cleaned and packaged           
          sunglasses to prepare them for distribution.  All of those ac-              
          tivities were necessary and essential to the assembly by B&L                
          Ireland and by B&L Hong Kong of the purchased sunglass parts into           
          finished, quality sunglasses that met B&L's quality standards and           
          that were ready for sale to the ultimate consumers.                         
               Respondent also argues that the respective assembly opera-             
          tions conducted by B&L Ireland and B&L Hong Kong were not sub-              
          stantial in nature when compared to the fabrication of the parts            
          used in those operations.  Respondent's argument misses the mark.           
          Section 1.954-3(a)(4)(iii), Income Tax Regs., requires a deter-             
          mination of whether "the operations conducted by the selling                
          corporation in connection with the property purchased and sold              
          are substantial in nature".  Under those regulations, we examine            
          the distinct operations conducted by the CFC with respect to the            
          purchased property to determine if those operations, standing               
          alone and without regard to the operations conducted by the                 





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