- 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 notPage: Previous 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 Next
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