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During the years in issue, services generally performed by
petitioner on behalf of the growers it represented, both related
and unrelated, included:
(a) Hiring Mexican customs brokers to arrange for
border inspections and clearing activities by Mexican
customs, the DOA, and Mexican trade associations;
(b) hiring U.S. customs brokers to arrange for
inspection and clearing activities on the U.S. side of the
border;
(c) paying border-crossing fees and charges, which then
were charged directly to the growers' accounts;
(d) for 1989, 1990, and 1991, paying Mexican labor
expenses for loading and unloading produce to be inspected
on the Mexican side of the border, which were not charged to
the growers;
(e) paying Mexican legal expenses incurred with respect
to border crossings, which were not charged to the growers;
(f) storing the growers' produce at petitioner's
distribution warehouses in Nogales, Arizona, and/or San
Diego, California;
(g) paying laborers for unloading the produce at the
warehouses;
(h) inspecting the produce at the warehouses for
damage, perishability, and disease;
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