- 5 -
Productora ABC (Productora).3 The parties stipulated that Mr.
Canelos controlled petitioner and the Canelos growers within the
meaning of section 1.482-1(a)(3) through (5), Income Tax Regs.
The Canelos growers have been distributing produce in Mexico for
almost as long as they have been distributing produce in the
United States, and the Canelos growers have established
relationships with Mexican buyers. They operated out of Mr.
Canelos' main office in Culiacan, Sinaloa, Mexico. Hereinafter,
we will refer to petitioner and the Canelos growers collectively
as the Canelos group; to Mr. Canelos and his brother Constantino
Canelos Rodriguez (Constantino) collectively as the Canelos
brothers; to the Canelos brothers and members of their families
collectively as the Canelos family; and to the Canelos family and
their related businesses collectively as the Canelos
organization. The Canelos organization functioned as a
vertically integrated operation with farming, packing, and
trucking operations in Mexico and sales and distribution
operations in the United States.
For the years in issue, the Canelos growers' produce sales
accounted for 98.76 percent, 99.28 percent, 89.24 percent, and
95.87 percent, respectively, of petitioner's total sales.
3Although the entities under which the Canelos growers
operated changed names during the years in issue, the majority of
the members remained the same.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011