GAC Produce Co., Inc., An Arizona Corporation - Page 11




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              Petitioner had approximately 10 people in its accounting                 
         section.  It contracted with RCLA to perform the sales function.              
         Relationship With Dole                                                        
              In November 1981, the Canelos group began doing business                 
         with Dole Food Co. (Dole),6  Dole, a publicly held company, or                
         some of its subsidiaries or affiliated companies.  Hereinafter,               
         Dole and its subsidiaries or affiliated companies collectively                
         will be referred to as Dole.  The business relationship between               
         the Canelos group and Dole constituted a joint venture.                       
              The first agreement between Dole and the Canelos group was a             
         1-year contract (1981 contract), entitled "Sales Subagency                    
         Agreement", in which petitioner and Standard Fruit and Steamship              
         Co. (Standard Fruit), a company affiliated with Dole, were the                
         designated parties.  In the 1981 contract, Standard Fruit agreed              
         to use its marketing resources to market more effectively in the              
         United States and Canada tomatoes, cucumbers, and bell peppers                
         grown by the Canelos growers in the Culiacan district of Mexico.              
         Standard Fruit would receive a commission of 25 percent of total              
         profit of each product, computed after subtracting from total                 
         revenue (from sales of the product by Standard Fruit, petitioner,             


               6Some documents in the record refer to Castle & Cooke, Inc.,            
          rather than to Dole.  Although the exact business relationship is            
          not explained in the record, it appears that Dole Food Co. was a             
          division of Castle & Cooke, Inc., for at least some portion of               
          the years in issue.   For simplicity, we will use the name Dole              
          throughout.                                                                  




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