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(2) Was the $5,100 that Mr. Palmer received during 1995
with respect to petitioners’ California house rental income or
compensation for that year? We hold that that amount was compen-
sation.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Redding, California, at the time the
petition was filed.
Mr. Palmer received a bachelor’s degree in chemical engi-
neering in 1969, a master’s degree in finance in 1972, and a law
degree in 1990.
In 1974, Mr. Palmer began working as a chemical engineer for
Aerojet General Corporation (Aerojet), a U.S. defense contractor.
Mr. Palmer held a number of positions during the approximate 20-
year period of his employment with Aerojet. The last position
that he held while employed by Aerojet was vice president of
operations of the high-tech bullet plant in Downey, California
(Downey plant), that Aerojet’s ordnance division (Aerojet Ord-
nance) operated.
In 1994, Olin Corporation (Olin), which was primarily a U.S.
defense contractor, acquired Aerojet Ordnance, including its
Downey plant, on behalf of Olin’s ordnance division (Olin Ord-
nance), an ammunitions manufacturer. Because of Mr. Palmer’s
experience with Aerojet Ordnance and, in particular, with the
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