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exhibits, are incorporated herein by this reference. At the time
their respective petitions were filed, petitioners resided in
Indianapolis, Indiana.
Personal, Educational, and Occupational Background
Petitioners are husband and wife and are the parents of
eight children. As of the date of the gifts at issue, they were
also the grandparents of 25 minor grandchildren.
A.J. Hackl was born on December 29, 1925, and Christine
Hackl was born on June 16, 1927. Since obtaining a Bachelor of
Mechanical Engineering degree from Georgia Institute of
Technology in 1946, A.J. Hackl has pursued a successful career in
business. He was employed by The Trane Company from 1946 to
1959, during which time he became a licensed professional
engineer and worked in several management positions. He next
accepted employment with Worthington Corporation, serving in
management and executive capacities within the company’s air
conditioning division from 1959 to 1968. Then, from 1968 until
his retirement in 1995, A.J. Hackl served as chief executive
officer of Herff Jones, Inc. During that period, Herff Jones
grew from a small, publicly held manufacturer of scholastic
recognition and motivational awards, with $18 million in annual
sales, to a national company with a broad line of products and
annual sales of $265 million. At the time of his retirement in
1995, A.J. Hackl owned a significant amount of Herff Jones stock,
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