Alain and Monique Massot - Page 2

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            as a result of the termination of his employment is excludable from                        
            petitioners’ gross income pursuant to section 104(a)(2).                                   
                  Unless otherwise indicated, all section references are to the                        
            Internal Revenue Code as in effect for the year in issue, and all                          
            Rule references are to the Tax Court Rules of Practice and                                 
                                         FINDINGS OF FACT                                              
                  Some of the facts have been stipulated and are so found.  The                        
            stipulations of facts and attached exhibits are incorporated herein                        
            by this reference.                                                                         
                  Petitioners resided in Arlington, Massachusetts, at the time                         
            they filed their petition.  They timely filed a joint 1992 income                          
            tax return.                                                                                
                  Petitioner was born and raised in Brittany, France.  He                              
            studied at the Institute of Chemistry of Paris, Sorbonne                                   
            University, receiving a degree in chemical engineering in 1970.                            
            Millipore, S.A. and Millipore Corp.                                                        
                  As of September 22, 1992, petitioner was the corporate vice                          
            president for marketing of Millipore Corp. (Millipore), a Fortune                          
            500 company, and a member of its 12-person executive committee.                            
                  Millipore’s business originally was based on the manufacturing                       
            and sale of precise membrane filters capable of removing bacteria                          
            and other harmful particles so as to purify water, air, gas, and                           

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