GAC Produce Co., Inc., An Arizona Corporation - Page 46




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         buy, not in the quality of the product.  Thus, Dr. Frisch                     
         concluded, it would be inappropriate to use Apache's transactions             
         as comparables for petitioner's transactions with the Canelos                 
         growers.                                                                      
              With respect to Bud Antle, Dr. Frisch asserted that, because             
         Bud Antle was related to SCP and Dole, the commissions paid to it             
         for marketing the Canelos growers' celery, lettuce, and brussels              
         sprouts may have been affected by other aspects of the                        
         relationship between SCP and the Canelos group.  Additionally,                
         Dr. Frisch also stated that, because petitioner and Bud Antle                 
         shared the commissions, it was not clear that Bud Antle performed             
         the full range of marketing functions; instead, it may have                   
         merely assisted petitioner.                                                   
              Dr. Frisch concluded that the 10-percent commission rate                 
         petitioner charged the otros growers was consistent with the 8-               
         to 12-percent commission rates U.S. distributors charged for                  
         selling Mexican produce in Nogales, Arizona, and other places as              
         stated in a study entitled "Competition in the U.S. Fresh                     
         Vegetable Industry", written by John A. VanSickle, Emil                       
         Belibasis, Dan Cantliffe, Gary Thompson, and Norm Oebker, and                 
         published by the U.S. Department of Agriculture, Economic                     
         Research Service, Agricultural Economic Report No. 691 (July                  
         1994).  Dr. Frisch stated that petitioner's commission rate                   
         received from the otros growers was generally in line with                    





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