Alfred E. Gallade - Page 3

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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,              
               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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