- 89 -
Ireland and B&L Hong Kong as manufacturing or production. See
Webb Export Corp. v. Commissioner, 91 T.C at 148. For example,
Peter McNally, who was the production manager of B&L Ireland's
sunglass assembly operations, testified: "The sunglass operation
[conducted by B&L Ireland] is generally known as the Sunglass
Manufacturing Plant because it was the center for the manufactur-
ing of sunglasses for the European and Middle Eastern market."
Petitioners also argue that the respective assembly opera-
tions conducted by B&L Ireland and B&L Hong Kong were generally
considered to constitute the manufacture of sunglasses from
various other perspectives. Both B&L Ireland and B&L Hong Kong
used standard cost accounting to assist their management. Mr.
Holdren, a C.P.A. relied upon by petitioners as an expert wit-
ness, concluded that the type and complexity of the respective
cost accounting systems utilized by B&L Ireland and B&L Hong Kong
are indicative of manufacturing companies and not distribution
operations. Thus, both B&L Ireland and B&L Hong Kong used the
types of accounting systems utilized by companies engaged in the
manufacture of products.
We also note that the Government of Ireland generally con-
sidered the assembly operations conducted by B&L Ireland to
constitute the manufacture of sunglasses. Prior to the time
during 1982 at which B&L Ireland initiated it sunglass assembly
operations, the IDA awarded B&L Ireland both capital and training
Page: Previous 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 NextLast modified: May 25, 2011