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current liabilities. At the end of 1989, that total liability
was $343,470, and, at the end of 1990, it was $624,880.
The Food Shows
In 1989 and 1990, petitioner conducted its annual food shows
in Amarillo, Texas. These shows were not open to the public.
Each vendor entered into an agreement with petitioner governing
the vendor's participation in the food show. The food-show
"agreement to participate" generally provided that: (1) The
vendor would pay $450 as a booth and participation fee; (2) the
vendor would properly decorate its booth and provide merchandise
samples; and (3) the vendor would offer approved special
promotions, allowances, and/or special buys on products, with the
condition that all offers must be a "real show special".
Furthermore, vendors had to agree to submit a recommended list of
show sale items to petitioner, which retained the right of
approval or rejection on all of the individual items. Petitioner
recovered the expense it incurred in sponsoring the food show
through the sale of space.
In preparation for each food show, petitioner asked the
participating vendors to complete order forms. These forms had
spaces to identify the vendor, the product being promoted, and
the per-unit promotional allowance offered for each product. The
vendors completed the order forms and returned them to
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