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Petitioner worked with a large number of outside contractors
to provide all its products. For any given garment, petitioner
would typically work closely with other companies to design the
garment and with manufacturers to develop and approve product
samples, coordinate raw materials production, and insure that
quality products were delivered on a timely basis. Bid proposals
and product samples were solicited from several manufacturers,
and petitioner would contract for specific production amounts
with one or more manufacturers. During each of the fiscal years
1990 through 1992, petitioner purchased clothing products from 25
to 50 different manufacturers.
Prior to petitioner's 1992 fiscal year, completed products
were delivered to petitioner at one of six warehouses in San
Antonio, Texas. Sometime in fiscal year 1991, Mr. Bennett hired
the architects and the builder and found the land to build a new
150,000-square foot distribution center to improve petitioner's
inventory management and customer service capabilities. Mr.
Bennett also contracted for a computerized state-of-the-art
inventory tracking system to provide for more efficient order
picking, packing, and billing operations. Mr. Bennett also
implemented additional technological advancements, such as wire-
guided forklifts for the new distribution center.
As petitioner's president, Mr. Bennett was in charge of day-
to-day operations. During petitioner's formative years, Mr.
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