-4-
and processes it into dairy products. Petitioner reports its
income using the accrual method of accounting. Petitioner's
fiscal year ends on March 31.
2. The Gustafson Family
Agnes and Frank Gustafson established a dairy in Green Cove
Springs, Florida, in 1908. They moved it to the present location
in the 1920's, and incorporated petitioner in 1954.
Agnes and Frank Gustafson had six children. Three of their
children died before the years in issue: F.N. (Noel) Gustafson,
Helen Gustafson Amara, and Julia Gustafson Bagley. G.J. (Pete)
Gustafson died in 1995. Two of their children were alive at the
time of trial: E.S. Gustafson (age 80) and Ellen Gustafson
Townsend (age 82). E.S. (Sherwood) Gustafson, Jr., is the son of
E.S. Gustafson.
3. Officers and Stock Ownership
Pete and Noel Gustafson worked full time for petitioner.
Noel Gustafson was president and manager of petitioner until he
died in 1984. E.S. Gustafson became petitioner's president and
chief executive officer in 1986 and remained in that position
through the years in issue. Sherwood Gustafson was the executive
vice president and general manager in the years in issue. E.S.
Gustafson and Sherwood Gustafson have worked for petitioner all
of their adult lives. E.S. Gustafson ran petitioner and was
involved in virtually all aspects of petitioner's business in the
years in issue.
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