GAC Produce Co., Inc., An Arizona Corporation - Page 6




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         Petitioner had the following sales and volume activity relating               
         to the Canelos growers for the years in issue:                                
                   FYE              Sales               Boxes                          
         1989           $43,037,000          6,209,000                                 
         1990            63,445,000          6,188,000                                 
         1991            29,013,000          3,915,000                                 
         1992            22,755,000          2,099,000                                 

             Petitioner's main selling season ran from November through               
         mid-May.  It worked solely on commission, and, except for produce             
         sold through Robling & Cathey, L.A., Inc. (RCLA),4 a company                  
         owned by the Canelos brothers, petitioner did not take title to               
         the produce it distributed.                                                   
              In addition to the Canelos growers' produce, petitioner                  
         distributed produce for independent Mexican growers (otros                    
         growers) not related to or controlled by the Canelos family.  The             
         otros growers generally were small growers who produced a                     
         different line of produce (e.g., grapes, European cucumbers,                  
         squash, melons) from the main lines of produce handled by the                 
         Canelos group.  None of the otros growers shipped tomatoes.                   





               4RCLA Division functioned as a separate division of                     
          petitioner until petitioner sold the division's assets to RCLA               
          effective June 30, 1990.  RCLA was owned by International Farm               
          Equipment Distributors, Inc., a Liberian corporation owned                   
          equally by Mr. Canelos and Constantino.  Produce sold through                
          RCLA is not in issue in the instant cases.                                   




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