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6651(a)(1) and 6656 (with regard to the withholding of income tax
at source).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulations of facts and the attached exhibits are incorporated
herein by this reference.
Background
Union Ganadera Regional de Chihuahua (Union Mexico) was a
Mexican, nonprofit agricultural cooperative, established in 1936.
It was organized to assist its members (namely, 43 individual
cattle associations, totaling approximately 3,000 Mexican cattle
ranchers) in the crossing of cattle from Mexico into the United
States and vice versa. Union Mexico was the parent company of Union
Ganadera Regional de Chihuahua, Inc. (petitioner), a New Mexico
corporation organized in 1991. At all relevant times, petitioner
maintained its principal place of business in Santa Teresa, New
Mexico.
Petitioner assisted Union Mexico in the crossing of cattle
over the U.S.-Mexican border. It employed eight individuals in
conducting its cattle-crossing activities on the U.S. side of the
border; whereas, Union Mexico employed 45 individuals in conducting
its cattle-crossing activities on the Mexican side of the border.
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