- 99 -
In addition, certain income of B&L Hong Kong from the sale
of B&L products it did not assemble is not at issue for petition-
ers' taxable years ended December 25, 1983, through December 28,
1986. Specifically, the record discloses that neither the income
of B&L Hong Kong from the sale of B&L products for use or con-
sumption in Hong Kong, see sec. 954(d)(1)(B), nor its income
during petitioners' taxable year ended December 30, 1984, from
the sale of products purchased from B&L Ireland, see sec. 1.954-
1(b)(4)(iii)(a), Income Tax Regs., is at issue. It is not clear
from the record whether any other income of B&L Hong Kong from
the sale of B&L products it did not assemble is at issue. How-
ever, we presume that the parties will exclude any such income
that is not at issue when making their computations herein under
Rule 155.
We now turn to the parties' arguments under section
954(b)(4) relating to B&L Hong Kong's income from the sale of B&L
products it did not assemble and from interest that the parties
and/or the record make clear is at issue. Respondent argues that
she did not abuse her discretion under section 954(b)(4) by
failing to exclude the income at issue of B&L Hong Kong from the
sale of B&L products it did not assemble and from interest from
petitioners' gross income for their taxable years ended December
25, 1983, through December 28, 1986. Although the record in
these cases might support a finding that B&L Hong Kong was not
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