John R. and Sara E. Wise - Page 3

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          trust that made investments in commercial real estate. MIP was not          
          a WC subsidiary but was managed by WC.                                      
               During the year in issue, petitioner managed all of WC's               
          financial service subsidiaries and was responsible for                      
          approximately 2,000 employees.  He was one of the 10 most highly            
          compensated individuals at WC, earning a base salary of $279,232.56         
          in 1989.  Petitioner did not have a written contract with WMC or            
               Although WC policy required that employees receive annual              
          employment reviews, petitioner never received such a review.                
          Nevertheless, he always received bonuses when he became eligible.           
                Between 1980 and April 1989, John W. Creighton served as              
          petitioner's immediate supervisor.  Mr. Creighton and petitioner            
          were close friends.  At the time of trial, Mr. Creighton was the            
          chief executive officer and chairman of the board of WC.                    
               Within WC's financial services chain of command, petitioner            
          was the number 3 person, below George Weyerhaeuser and Mr.                  
          Communications Before Petitioner's Termination                              
               In 1988, petitioner expressed a concern to Mr. Creighton that          
          because of the developing trend to consolidate in the mortgage              
          banking industry, there was a strong possibility that WC would              
          sell WMC, which might then leave petitioner unemployed. In response         
          to this concern, Mr. Creighton orally assured petitioner that WC            

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