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to perform these experiments. In high school, petitioner studied
chemistry. In college, petitioner majored in chemistry,
mathematics, and physics. Petitioner also had performed some
electrical engineering course work. Subsequently, petitioner
terminated his college education in order to work full time as an
electrical technician. Later, petitioner independently started a
part-time business entailing the purchase of laboratory
instruments at U.S. Government surplus sales. Then, he
reconditioned and resold these items to laboratories.
In March 1977, petitioner began working full time on his own
behalf. His desire at that time was to be "self-employed" in
order to do technical research and development. Petitioner would
engineer, fabricate and service controls for industrial fine
equipment. These operations were petitioner’s primary income
during 1977 and 1978.
In 1979, petitioner began to experiment with recovering
mercury from scrap batteries obtained from the U.S. General
Services Administration and U.S. Department of Defense (DOD)
surplus sales. Petitioner was spurred by the fact that in 1978
the price of mercury increased in the New York commodities market
from slightly more than $1 a pound to close to $3 a pound. In
past years, the price of mercury had been close to $1 dollar a
pound. The surplus scrap batteries purchased ranged from watch
batteries to 20-pound batteries. Petitioner developed a
technique to extract and refine mercury from scrap batteries and
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