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those services. Petitioner's major expenses were fixed costs,
although it had some capital investments in warehouses and
equipment.
For years ending 1980 through 1994, petitioner reported the
following taxable income, before net operating loss deductions or
carryovers:
FYE Income
1980 $52,621
1981 13,169
1982 186,148
1983 228,346
1984 204,601
1985 86,863
1986 (680,868)
1987 (908,015)
1988 (116,678)
1989 (740,114)
1990 (308,478)
1991 (1,538,326)
1992 (1,565,929)
1993 (213,587)
1994 411,827
During the years in issue, petitioner primarily sold
tomatoes, but it also marketed other produce, including
cucumbers, bell peppers, melons, and grapes. During those years,
petitioner distributed produce for Mexican growers (Canelos
growers) that were related to and controlled by Mr. Canelos. For
the years in issue, the Canelos growers operated under various
names, including Canelos Hermanos, Frutas y Vegetales Del Valle
(Frutave), Administradora Horticola Del Tamazula (Adhota), and
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