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Petitioner earned a master's degree in industrial
engineering in 1963 and a Ph.D. in managerial economics in 1975.
He has been a licensed professional engineer in industrial
engineering and has been a member of the American Institute of
Industrial Engineers, the American Society of Mechanical
Engineers, and the National Society of Professional Engineers.
Petitioner's professional experience includes employment with
Standard Brands, Exxon Corp., Mobil Corp. (Mobil), and the
Celanese Corp. (Celanese). At Mobil, petitioner worked as a
financial analyst, a project manager for distribution facilities,
and as a senior consultant for marketing and distribution in
Mobil's international division. In the latter capacity he was
employed in analysis of the economics of the oil business.
Petitioner left Mobil after 10 years and in 1974 joined Celanese,
where he remained employed through the tax years in issue.
Petitioner started at Celanese as manager of the
hydrocarbons planning group of the company, which was the largest
merchant buyer of ethylene in the United States. Celanese's
primary business concerned hydrocarbons--plastics, chemicals, and
fibers. According to petitioner, at one point Celanese was the
100th largest corporation in the United States and had revenues
of approximately $4 billion. Celanese subscribed to services
provided by nearly every major forecasting entity, including
Arthur D. Little, Inc., the Stanford Research Institute, and Data
Resources, Inc. It budgeted approximately $500,000 annually for
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