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petitioner relinquished the chairmanship but remained employed as
a full-time professor. In 1993, petitioner retired as professor
emeritus.
By the mid-1970's, petitioner was disenchanted with academic
life, felt that he was "highly underemployed", and was utilizing
only a "small fraction of his knowledge in teaching political
science courses." In 1975, petitioner decided to look for an
"executive position" with several international corporations,
with the expectation that he could use his multidisciplinary
background to achieve higher employment status and a higher
salary. While the corporations petitioner contacted were
impressed with his background, petitioner was unable to secure
employment because he was approaching the age of 60. By 1977,
petitioner decided to form his own corporation in an effort to
achieve his goals.
In March 1977, petitioner and another individual, Peter
Takos, Jr. (Mr. Takos), formed International Management and
Investment Corp. (the corporation), an Iowa corporation, to find
"appropriate properties in the United States for overseas
investors". Investors would be charged commissions and fees for
the services rendered. Petitioner and Mr. Takos contributed
$20,000 each as initial corporate capital. Petitioner was
executive vice president and secretary of the corporation, while
Mr. Takos served as president and treasurer.
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