Gustafson's Dairy, Inc. - Page 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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