GAC Produce Co., Inc., An Arizona Corporation - Page 20




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         petitioner never sold more than the number of boxes sold in the               
         year ending 1985.                                                             
              The SCP contract began in June 1985, and the first sales                 
         under the contract were reported on petitioner's tax return for               
         the year ending 1986.  Petitioner showed losses on its tax                    
         returns for all the years beginning with and following year                   
         ending 1986.                                                                  
              The SCP contract provided for an automatic 5-year extension              
         absent notice of revocation given 1 year before its June 15,                  
         1990, expiration date.  In 1990, the SCP contract was extended                
         automatically for 5 years when petitioner did not give SCP a                  
         notice of cancellation by June 16, 1989.                                      
              The Canelos growers did not pay U.S. income taxes on their               
         share of the profits earned under the SCP contract.                           
              Petitioner, the Canelos growers, and SCP terminated the SCP              
         deal and extinguished all their obligations and business                      
         relationships under the SCP contract effective May 14, 1993.  As              
         part of the termination agreement and settlement of accounts                  
         between the Canelos group and SCP, the Canelos brothers and their             
         related entities repaid advances SCP had made to petitioner.                  
         The Canelos Organization                                                      
              During the years in issue, the Canelos brothers used Canelos             
         Hermanos, an unincorporated business association, as the name of              
         the farming operations they jointly owned and operated.  Canelos              





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