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were married in 1978 and remained married at the time of trial.
Petitioner and Mr. Bilzerian both graduated from Stanford
University. After graduating from Stanford, Mr. Bilzerian
attended Harvard University and graduated in 1977 with a master’s
degree in business administration. After graduating from
Harvard, Mr. Bilzerian worked in the real estate business. In
1982, Mr. Bilzerian began trading securities. Before 1987, Mr.
Bilzerian either explored the possibility of taking over control,
or attempted to take over control, of several publicly traded
companies, including Hammermill Paper Co. (Hammermill), Armco,
Cluett Peabody, H.H. Robertson, and Syntex Corp.
In 1986, Mr. Bilzerian and Earl and Billy Mack (the Macks)
formed a partnership, Bilzerian & Mack Associates (Bilzerian &
Mack), for the purpose of launching a takeover of Hammermill.
Mr. Bilzerian was a general partner of Bilzerian & Mack, and he
signed the partnership return for 1986 on March 23, 1987. Mack
Asset Co. and Bilzerian Investors, two partnerships, were
reported on Bilzerian & Mack’s 1986 Form 1065, U.S. Partnership
Return of Income, as other general partners. Mr. Bilzerian was
involved in Bilzerian Investors and another partnership named
Bilzerian Ventures. Although Hammermill was eventually acquired
by International Paper Co. in August of 1986, Mr. Bilzerian
realized substantial gains in 1986 through Bilzerian & Mack,
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