Requests for Importer Ruling
FRESH GARLIC ORIGINATING IN OR EXPORTED FROM THE
PEOPLE’S REPUBLIC OF CHINA
Request No.: MP-97-001
TABLE OF CONTENTS
Ottawa, Friday, September 4, 1998
Request No.: MP-97-001
IN THE MATTER OF a ruling under section 90 of the Special
Import Measures Act, R.S.C. 1985, c. S-15, as amended, on the
question of which of two persons is the importer in Canada of:
FRESH GARLIC ORIGINATING IN OR EXPORTED FROM
THE PEOPLE’S REPUBLIC OF CHINA
The Canadian International Trade Tribunal conducted an inquiry,
pursuant to section 90 of the Special Import Measures Act,
relative to a request by the Deputy Minister of National Revenue,
on behalf of D & L Business Canada Ltd., for a ruling on the
question of which of two persons is the importer in Canada of fresh
garlic originating in or exported from the People’s Republic of
The Canadian International Trade Tribunal hereby rules that the
importer in Canada of the said goods is D & L Business Canada
Ltd. (Member Gracey dissenting).
Robert C. Coates, Q.C.
Robert C. Coates, Q.C.
Charles A. Gracey
Charles A. Gracey
Michel P. Granger
Michel P. Granger
On December 1, 1997, the Deputy Minister of National Revenue
(the Deputy Minister) made a request to the Canadian International
Trade Tribunal (the Tribunal) for a ruling, pursuant to subsection
89(1) of the Special Import Measures Act  (SIMA), on who is the importer in
Canada of fresh garlic originating in or exported from the People’s
Republic of China (China). This request was initiated on behalf of
D & L Business Canada Ltd. (D & L).
On March 21, 1997, the Tribunal found, pursuant to subsection
43(1) of SIMA, that the dumping in Canada of fresh garlic
originating in or exported from China had caused material injury to
the domestic industry.  The finding applies only to fresh garlic imported
into Canada from China from July 1 to December 31, inclusive, of
each calendar year.
The Deputy Minister’s request concerns two importations of fresh
garlic in late 1996 when provisional anti-dumping duties were
payable. At the time of importation, D & L was identified as
the importer of record, and this position was not questioned by the
Department of National Revenue (Revenue Canada). On September 8,
1997, a partial refund of the provisional anti-dumping duties was
paid in accordance with section 55 of SIMA. However, the Pacific
Region Customs Investigations Division of Revenue Canada
investigated the importations and concluded that D & L made
false statements in accounting for the goods and that, by
overvaluing the declared value for duty, it had avoided payment of
provisional anti-dumping duties. As a result, a penalty of some
$335,000 was assessed against D & L, which appealed the
assessment and, in conjunction with this appeal, contended that the
importer of the two shipments was Shengli Group U.S.A. (Shengli),
the exporter of record, and not D & L. As a consequence, D
& L requested that the question of who is the importer of the
goods be referred to the Tribunal under paragraph 89(1)(b)
On December 11, 1997, the Tribunal issued a notice of request
for a ruling. It invited interested parties to file written
submissions containing relevant facts, documents and arguments in
support of any views pertinent to the making of the ruling by
January 19, 1998. Notices of appearance, as well as declarations
and undertakings, were to be filed with the Secretary on or before
January 12, 1998. The Tribunal received public submissions and
notices of appearance from the Deputy Minister, D & L and
Shengli. The Tribunal also received confidential submissions from
the Deputy Minister and D & L.
On February 26, 1998, the Tribunal notified counsel and parties
that it would hold a public hearing in Vancouver, British Columbia,
on May 4, 1998. Parties intending to participate in the hearing had
to advise the Secretary on or before April 14, 1998. At the same
time, parties were invited to file with the Tribunal their witness
statements and any additional submissions. The Deputy Minister and
D & L informed the Tribunal that they would participate in the
hearing. They also filed additional submissions.
Two witnesses testified at the hearing: Mr. Robert Head, an
investigator with the Pacific Region Customs Investigations
Division of Revenue Canada; and Mr. Dodge D. Li, one of the owners
of D & L. The relevant facts in the present case can be
summarized as follows.
On November 21, 1996, provisional anti-dumping duties were
imposed on fresh garlic imported from China. In January 1997, an
officer assigned to the Trade Administration Services Unit in
Vancouver received a complaint from a local importer/wholesaler
that D & L was offering Chinese garlic for sale in the
Vancouver area at a price which did not reflect the anti-dumping
duties in effect at the time. D & L is a small consulting firm
located in Vancouver, which specializes in facilitating business
exchanges between persons in China and Canada. It is operated from
the residence of its two directors, Mr. Li and his wife, Ms. Queen
The investigation revealed that 11 containers of garlic were
exported from China in July 1996 to the state of California.
However, the garlic never entered the US market. It was kept in
cold storage for four months. In late November 1996, the 11
containers were trucked across the Canadian border. The garlic was
subsequently kept in cold storage in Vancouver, after the
anti-dumping duties were paid by D & L. Over a four-month
period, namely, between December 1996 and March 1997, the garlic
was sold in the Vancouver area to retailers, wholesalers and
restaurants. The garlic was marketed by a US resident named Ms.
Flora Lee, an employee of both Mayland Enterprises (U.S.A.), Inc.
(Mayland) and Shengli, the exporter of record.
On April 29, 1997, a number of documents, including records of
sales, bank deposits, records of telephone conversations,
solicitations to sell garlic to various Canadian retailers and cold
storage documents, were seized at the residence of the principals
of D & L. Bank records showed that over $200,000 had been
deposited into a bank account, which was set up by Mr. Li and Ms.
Lee. The account was opened in the name of D & L Business
Canada Limited (U.S.) on November 28, 1996, with a $15,000 cheque
drawn in the name of Mayland and made payable to D & L. At the
insistence of Mr. Li, cheques drawn from the account required two
signatures, namely, those of Mr. Li and Ms. Lee. Most of the money
was wired to bank accounts in California, either to Shengli or to
Mr. Jian Guo Xu, a principal of Shengli.
The customs cargo control document, which is one of several
documents included with the customs entry, identified Shengli as
the shipper and D & L as the consignee, while the Customs
Automated Data Exchange (CADEX) lead sheets, which are submitted to
Revenue Canada by the customs broker to facilitate the clearance of
the goods, identified D & L as the importer. The invoices also
indicated that the goods were to be shipped and billed to D &
L. Correspondence dated November 18, 1996, between a Vancouver area
cold storage facility and Quinn Li of D & L, explaining such
things as quotes for cold storage and shipping and receiving hours,
was also seized.
Documents showed that payments by Vancouver area purchasers of
the imported garlic were made to D & L. The money was deposited
into the D & L Business Canada Limited (U.S.) bank account.
Because there was no evidence of a sale of the garlic from Shengli
to D & L, a value for duty opinion was requested from an
evaluation specialist. This resulted in a notice of ascertained
forfeiture to D & L, which demanded payment of $335,571.67,
representing the total difference between the normal value of
$1.91/kg then in effect and the true value for duty of the goods of
$0.97/kg, plus a penalty.
At no time, prior to asking the Deputy Minister to request a
ruling from the Tribunal, did D & L question or object to its
status as the importer of the subject garlic.
Both Mr. Li and Ms. Deng were born and educated in China. On
November 17, 1996, Ms. Lee, who had met Ms. Deng in China,
contacted her to advise her that she was now in the United States
working for Mayland, a sister company to Shengli. Ms. Lee indicated
that she needed a Canadian company to import garlic for Mayland
into Canada. She also asked Ms. Deng to make inquiries concerning
storage arrangements for the garlic. When in Canada, she asked Ms.
Deng and Mr. Li to drive her around Vancouver so she could
familiarize herself with the city and also meet prospective
purchasers of the garlic. Mr. Li testified that Ms. Lee knew all of
the customers before she came to Vancouver and that he and his wife
did not introduce her to any of them. Mr. Li and Ms. Deng also
agreed to let her use their office facilities in order to conduct
her business. In exchange for these services, D & L received a
commission of US$2,000. The D & L Business Canada Limited
(U.S.) bank account, to which D & L made no contribution, was
used to pay Ms. Lee’s expenses and to receive the proceeds of
sales. It was used to pay for cold storage and all of the expenses
associated with the importation. For example, the D & L cheque
used to pay the anti-dumping duties was signed by Ms. Lee and Mr.
On or about November 25, 1996, an Agreement on Sales Assistance
in Canada (the Agreement) was concluded between Mayland and D &
L. It was signed by Mr. Li, on behalf of D & L, and Mr. Xu, on
behalf of Mayland. The Agreement provided that: Mayland would
arrange for the export of the goods to Vancouver; Mayland would
open a checking account in D & L’s name through which all sales
transactions would be made; Mayland would be responsible for import
duties and all the relative expenses caused by the sale; D & L
would offer its best assistance and help during the sales process;
and Mayland would pay US$2,000 to D & L as a commission for
offering all the assistance possible upon the termination of the
sales in Vancouver.
The Deputy Minister’s position is that D & L is the importer
of the subject garlic. Counsel for the Deputy Minister submitted
that D & L is the only one that the Tribunal may determine to
be the importer in Canada of the goods for the purposes of SIMA.
Pursuant to subsection 2(1) of SIMA, “importer” is defined, “in
relation to any goods,” as “the person who is in reality the
importer of the goods.” Counsel referred to the following statement
of Jackett J. in Her Majesty the Queen v. The Singer
The essential feature ... is that the exporter must be the
person in the foreign country who sends the goods into Canada and
the importer must be the person to whom they are sent in Canada.
According to counsel for the Deputy Minister, in making a ruling
under subsection 89(1) of SIMA, the only option available to the
Tribunal is to arrive at a ruling by determining which of the two
or more persons is the importer in Canada, and the Tribunal has no
jurisdiction to determine that a person outside Canada is the
importer in Canada. In counsel’s view, the entire scheme of SIMA
revolves around the concept that goods imported into Canada must
have an importer in Canada. Counsel referred to a number of
sections in SIMA which contain the words “importer in Canada” in
support of his argument. He argued that the simple fact that
Parliament has given jurisdiction to the Tribunal to determine who
is the importer in Canada is indicative of the fact that there must
be an importer in Canada of dumped goods.
Counsel for the Deputy Minister noted that, in the present case,
among the three candidates put forward for the Tribunal’s
determination, namely, D & L, Shengli and Mayland, and the
eventual purchasers of the subject garlic, it is clear that D &
L is the only one in Canada that can be the importer. The evidence
is clear that Shengli, a US-based company, exported the goods to
Canada and, therefore, as the exporter under SIMA, Shengli cannot
be the importer. Regarding the eventual purchasers of the subject
garlic, counsel argued that they cannot be the importer, as the
evidence clearly shows that, before they even heard of the garlic,
it was already in Canada. Counsel reviewed the evidence which, in
his view, supports the Deputy Minister’s position that D & L is
in reality the importer. Counsel argued that, if the Tribunal rules
that a company other than D & L is the importer, a substantial
amount of anti-dumping duties will have been evaded in a manner
which could easily be repeated by others to the detriment of both
domestic producers and other importers.
Counsel for the Deputy Minister argued that the business
relationship between D & L and Shengli was structured in such a
way that any company buying the subject garlic would assume that it
was dealing with a local supplier, namely, D & L. He argued
that this supports his argument that D & L was the importer and
that it had control and management of the garlic. Counsel submitted
that D & L could not have escaped liability vis-à-vis third
parties by virtue of its private arrangement with Shengli. He
argued that D & L would have been liable to third parties for
any problems regarding non-payment of bills, for example.
Counsel for the Deputy Minister reminded the Tribunal that its
mandate is not to determine whether the ascertained forfeiture is
appropriate. It is simply to determine who of two persons is the
importer of the subject garlic. He noted that a ruling that D &
L is the importer does not necessarily mean that Mr. Li and Ms.
Deng are going to lose their house. He also noted that an appeal of
the ascertained forfeiture has been filed by Mr. Li and Ms. Deng
and that there exists a possible recourse against Shengli for
execution of the Agreement. Counsel also reminded the Tribunal that
the Deputy Minister has discretion in deciding whether to enforce
an ascertained forfeiture and to actually collect the money
Finally, counsel for the Deputy Minister noted that Revenue
Canada does recognize non-resident importers under SIMA, however,
only on rare occasions and usually in advance of importation to
accommodate highly unique situations. The arrangements always
include a commitment from the non-resident importer to sell to
Canada at export prices or above the normal values so as to
eliminate dumping. If the export sales are to be made at dumped
prices, then there is a commitment from the non-resident importer
to pay the anti-dumping duties and to pass them on to the
purchasers in Canada and to provide supporting documentation to
Revenue Canada. Counsel noted that no such arrangement was made in
the present case between Shengli and Revenue Canada.
Counsel for D & L argued that non-resident importers are
permitted under SIMA. In his view, the fact that Revenue Canada
recognizes them in certain circumstances proves that they are
permitted. Counsel referred to a number of Tribunal findings where
Revenue Canada has recognized non-resident importers. In addition,
he noted that non-resident importers are recognized under the
Customs Act.  He also noted that the customs and tax departments
of Revenue Canada do business with non-resident importers. In
counsel’s view, to suggest that there can be non-resident importers
for the purposes of customs and taxes but not for the purposes of
SIMA sends the wrong message to Canada’s trading partners. He
argued that the definition of “importer” in SIMA has no residency
requirement. If Parliament had intended that importers be limited
to those who reside in Canada, it would have said so. Regarding
Singer, counsel argued that, in practice, the importer is
not always the person to whom the imported goods are sent in
Canada. He noted that a company in Vancouver can be the importer,
even though the goods are sent to a company in Toronto. In
counsel’s view, international trade has evolved to the point where
the exporter and the importer can be the same person.
In the view of counsel for D & L, if the “real” importer is
the one that caused the goods to be imported, then, in the present
case, the real importer can only be Shengli. Counsel acknowledged
that, for purposes of the Customs Act, D & L was the
importer of record; however, when reviewing the facts in the
present case, it is obvious that the “real” importer of the garlic
was Shengli. Counsel added that Revenue Canada could make
arrangements with Shengli for payment of the anti-dumping duties.
As a consequence, payment of the duties would not be evaded as
suggested by counsel for the Deputy Minister. In conclusion,
counsel for D & L submitted that, given the circumstances of
this case, to determine that D & L is the importer and to
require payment of $335,571.67 where it only realized a commission
of US$2,000 would be a travesty of justice. In view of the evidence
before the Tribunal, counsel asked that the Tribunal rule that the
importer of the imported garlic is Shengli and not D & L.
Shengli’s representative did not appear at the hearing. In his
written submission, he argued that Shengli was both the owner and
exporter of the garlic and that it enlisted the service of D &
L to assist with customs formalities and subsequent re-sale
activity, believing that it needed to be a resident in order to
import into Canada. Further, he submitted that, at all times,
Shengli retained title and control of the garlic up to the point of
resale in Canada and that all profits resulting from the sales were
for its benefit and not for the benefit of D & L.
In making a ruling under section 90 of SIMA as to who of two
persons is the importer in Canada of imported goods, the Tribunal
must take into account the object and purpose of the statute. In an
importer ruling, in Request No. IR-2-86,  the Canadian Import Tribunal (the CIT)
stated the following:
The liability for payment of anti-dumping duties is placed on
the importer of dumped goods. That is part of the general scheme to
deal with the mischief of dumping, to discourage it. The object of
the statute is to protect Canadian producers of goods from
injurious importations of dumped goods, and that is achieved by
imposing the burden of the special duty on the importer. If the
exporter, through its agent, pays the duty, the object of the
statute is not being achieved. 
The word “importer” is defined in subsection 2(1) of SIMA as
“the person who is in reality the importer of the goods.” In
Graphite Electrodes, the CIT was of the view that this
definition implied that the simple designation of a person or firm
on the customs entry documents as the so-called importer of record
had little meaning. The CIT stated that “the statute, in this
process of identification [of the real importer], has concern for
substance as opposed to form.  ”
In the present case, the Tribunal is faced with a difficult
situation. In the view of the majority of the Tribunal, the
evidence shows that D & L simply acted as an agent for Shengli
in Canada. There was no “real” transaction between these two
companies. Mr. Li and Ms. Deng simply permitted Ms. Lee to use
their company’s name to conduct her business in Canada on behalf of
Shengli. D & L did not pay for the imported garlic nor did it
ever take actual possession of it. Other than the US$2,000
commission, D & L did not profit from the resale of the subject
garlic to distributors, wholesalers and restaurants. The evidence
also shows that the importation was arranged by Shengli, and in
particular its employee, Ms. Lee. All that D & L was to provide
was its best assistance and help during the sales process pursuant
to the terms of the Agreement.
In Graphite Electrodes, the CIT was faced with a similar
situation, except that it had further evidence which showed that
numerous discussions had been held between a third party and the
exporter prior to importation. Indeed, this third party had placed
the actual purchase order for the imported goods in question. On
the basis of this evidence, the CIT found that the third party was
the “real” importer. The CIT held that the so-called “importer of
record” was simply a “paper intermediary,” i.e. an agent for the
exporter. There is no such evidence in the present case. The
Tribunal has two parties before it, namely, D & L (the
acknowledged importer of record) and Shengli, one of which must be
identified as the “real” importer of the subject garlic. Although
the evidence shows that the subject garlic was eventually sold to
retailers, wholesalers and restaurants in Canada, there is no
evidence of any dealings between any of these entities and Shengli
prior to importation.
Consequently, after having heard and reviewed all of the
evidence, including all of the documents which were filed by both
parties to this inquiry, the majority of the Tribunal is of the
view that, between D & L and Shengli, it has no choice but to
find that D & L is the importer in Canada of the subject
garlic. In the view of the majority of the Tribunal, to rule
otherwise and to find that Shengli is the importer in Canada of the
subject garlic would be contrary to the object of SIMA. Although
certain arrangements may be made between Revenue Canada and
non-resident importers with respect to the payment of anti-dumping
duties, as occurred in Inquiry No. NQ-91-006,  unfortunately for D & L, no such
arrangement was made in the present case.
Accordingly, pursuant to section 90 of SIMA, the majority of the
Tribunal hereby rules that the importer in Canada of the subject
garlic is D & L.
I respectfully dissent from the majority decision in this matter
for the following reasons.
It is not necessary to repeat all of the known facts in this
case. They have been adequately summarized in the majority
decision, and it is merely necessary for me to identify and
emphasize those facts and circumstances which have led to my
At issue in this inquiry is the question of who was the real
importer of the subject goods. In my view, the evidence points to
the conclusion that the real importer was Shengli and that D &
L was, at most, an agent of the importer.
I shall begin by making reference to the Agreement, which sets
out five terms which, in my view, are relevant to the outcome of
this case. Those terms are as follows:
· Party A [Mayland] will arrange the export of the goods to
• Party A will open a checking account under Party B’s name and
all the sales transaction[s] will be made through this account.
• Party A will be responsible for import duties and all the
relative expenses caused by the sales.
• Party B will offer its best assistance and help during the
• Party A should pay $2,000 to Party B as commission for
offering all the assistance possible upon the finish of the sales
The garlic was imported into Canada in two shipments and placed
in storage, and sales to customers commenced. All import documents
appeared to be in order, and it is relevant to note that the
release dates on the two customs entries/invoices were November 29
and December 5, 1996. This is relevant for two reasons. First, it
is noted that the first date of shipment was a scant 11 days after
the first contact with D & L. Second, the two invoices prepared
by Shengli, purportedly Mayland’s export arm, state “SHIP &
BILL TO: D & L Business Canada Ltd.” Each invoice bears the
signature of Mr. Xu, the same person who signed the Agreement.
Clearly the instruction to bill D & L is at variance with the
stated intent of the Agreement. The next observation is that the
invoices state that the “[d]ate of order” was November 2, 1996,
which predated the first contact between Ms. Lee and Ms. Deng by
about two weeks. Certainly there is no reason to disbelieve Mr.
Li’s claim that the first contact was made on November 17, 1996. As
the authorities had seized records, if there had been a contact
earlier than November 17, 1996, it would have been put on the
record. It is apparent that plans to export the goods to Canada
were well advanced, even before the initial contact was made with D
& L. In light of such unrefuted evidence, it is clear that
Shengli initiated and arranged for the importation.
The dates on the customs entries/invoices are also important,
inasmuch as they are subsequent to the date of the preliminary
determination of dumping made by Revenue Canada. But the date on
the invoices was November 20, 1996, one day before the issuance of
the preliminary determination of dumping.
The Deputy Minister, in my view, has a weak case. Fundamentally,
the case is weakened by the uncontested facts that D&L:
• did not initiate the importation;
• did not order the goods;
• did not ever pay for or take ownership or even physical
possession of the goods;
• did not sell the goods;
• did not receive into its own hands any of the proceeds from
the sale of the goods.
All that D & L realized was a very modest commission.
The Deputy Minister, however, takes the view that, in lending
its name to the activities, D & L became the importer of
record. Indeed, the name D & L appears on the import document
as the importer of record. However, it is obvious that the name of
the importer of record on import documents is not conclusive,
though it is surely indicative. But we are asked to determine who
in reality was the importer of the goods. I would argue that
Shengli was in reality the importer of the goods. In support of
that conclusion, it need only be noted that Shengli made the
initial contact with D & L and did not offer to sell it the
goods. Rather, it retained ownership of the goods and at no time
relinquished control of the goods to D & L. Shengli conceived
and executed the importation and the subsequent sale.
The Deputy Minister has relied heavily on the meaning to be
given, under SIMA, to the term “importer.” Counsel for the Deputy
Minister argued that, under SIMA, the importer must be an importer
in Canada. In my view, this overlooks the fact and the very common
practice of non-resident importers. Counsel referred to several
excerpts from SIMA, including sections in which the phrase
“importer in Canada” appears. No definition of the term was
offered, therefore, it falls to the Tribunal to determine its
meaning from the context in which it appears. Indeed, the central
question is the distinction, if any, between the term “importer in
Canada” and the simple noun “importer.” This question is
complicated by the fact that the term “importateur”
(“importer”) is unqualified by any reference to “au Canada”
(“in Canada”) in the French version.
Revenue Canada also relies upon the customs cargo control
documents, the CADEX lead sheets and the invoices, all of which
indicate that D & L is the importer or at least the importer of
record. This is surely prima facie evidence that merits
further investigation. That is why the Tribunal was asked to hear
this case. The prima facie evidence is quite strong, but not
so strong as to remove all doubt. In fact, as the Tribunal looked
into the matter, it became apparent that the customs cargo control
documents, the CADEX lead sheets and, of course, the invoices were
all prepared by Shengli or the import broker. There was no evidence
adduced that D & L had any knowledge of the information placed
on those documents and, as has been seen, some of that information
was false. It was Shengli that entered the instructions to “SHIP
& BILL TO: D & L” and that falsely declared the “[d]ate of
order.” The date declared, incidentally, is demonstrably wrong on
two counts. First, the goods were not ordered, they were sent.
Second, of course, the date is several days before the date of the
first contract made by Shengli to Ms. Deng and, thus, appears to
have been a fabrication.
The record is clear that the entire project was conceived and
executed by Shengli and that Ms. Lee exploited an earlier
friendship with Ms. Deng to make the arrangements and then to leave
D & L in a vulnerable position. In my view, the principals of D
& L were victims of a gross deception conceived and executed
under the pretext of a friendship by Ms. Lee of Shengli.
That D & L was not the real importer should be obvious. If,
for example, D & L had attempted to receive into its own hands
the proceeds of sales, Shengli would have had no difficulty in
proving that it had never sold the goods to D & L and that it
had no right to the proceeds of sales. Indeed, but for the prudent
insistence of Mr. Li, the bank account would have borne and
required only the signature of Ms. Lee. That D & L was foolish
to lend its company name to the enterprise is now apparent. But
this is the only very tenuous link to any claim that D & L was,
in fact, the importer and, in my view, it does not have as much
weight as the facts already recounted. The reason for a hearing was
to sort out what appeared, at first, to be a complex mix of events.
However, the evidence received at the hearing persuaded me that the
real importer of the subject goods was Shengli and that D & L
was no more than its paid agent.
Accordingly, pursuant to section 90 of SIMA, I hereby rule that
the importer of the subject goods is Shengli.
1. R.S.C. 1985 c.
S-15, as amended.
2. Fresh Garlic
Originating in or Exported from the People’s Republic of China,
Inquiry No. NQ-96-002 , Finding, March 21, 1997, Statement of
Reasons, April 7, 1997.
3.  1 Ex. C.R.
129 at 136.
4. R.S.C. 1985, c. 1
5. Certain Artificial
Graphite Electrodes and Connecting Pins Originating in or Exported
from the United States of America, Canadian Import Tribunal,
Importer Ruling and Statement of Reasons, May 1, 1987.
6. Ibid. at 5.
8. Machine Tufted
Carpeting Originating in or Exported from the United States of
America, Canadian International Trade Tribunal, Finding, April 21,
1992, Statement of Reasons, May 6, 1992.
[Table of Contents
Initial publication: September 4, 1998