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through December 29, 1979). They separated in November 1985, and
they were divorced a second time as of November 30, 1987.
In 1943, petitioner received a bachelor of science degree in
philosophy. After graduation, petitioner served in the U.S. Navy
for approximately 5 years, after which he returned to the Los
Angeles area to operate what he refers to as “small businesses”.
In the late 1940s, petitioner began working for Hughes Aircraft
Co. (Hughes) until approximately 1950, when he started a tire
distribution business. After working in this business,
petitioner returned to Hughes. Subsequently, petitioner was
hired by a chemical company as a general manager in Inglewood,
California.
After leaving the Inglewood chemical company, on January 2,
1970, petitioner incorporated his own chemical distribution
business, Gallade Chemical, Inc. (GCI), of which he was the sole
shareholder and officer. GCI maintained its principal place of
business in Santa Ana, California. Petitioner was employed by
GCI from its date of incorporation through the years in issue.
On December 1, 1970, GCI adopted a pension plan known as the
“Defined Benefit Pension Plan of Gallade Chemical, Inc.” (the
Plan), which, at all relevant times, was qualified under section
401(a). The First American Trust Co. (First American) was the
trustee of the Plan. Petitioner participated in the Plan from
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