Ernest I. Korchak - Page 6

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          notes.  In connection with these arrangements, PI, ECI, F&G, RRI,           
          and Madison entered into offset agreements so that the foregoing            
          payments were bookkeeping entries only and were never in fact               
          paid.10                                                                     
          Petitioner’s Education and Professional Experience                          
               In 1957, petitioner graduated from the University of                   
          Melbourne with a bachelor’s degree in chemical engineering.                 
          Petitioner worked for 2 years at Imperial Chemical Industries               
          (Imperial) in Australia and New Zealand as a research post                  
          engineer.  Petitioner worked on recycling and waste treatment               
          projects while at Imperial; his first project there involved                
          experimental work regarding the waste treatment of an aqueous               
          wetland stream from a chemical plant.  Petitioner also                      
          participated in projects at Imperial that involved the treatment            
          of internal streams for recycling.                                          
               In 1964, petitioner received a master’s degree and a Ph.D.             
          degree in chemical engineering from the Massachusetts Institute             
          of Technology (MIT).  While at MIT, petitioner worked                       
          intermittently for Monsanto Research Corp. (Monsanto) in Everett,           
          Massachusetts.  At Monsanto, petitioner performed experimental              
          work on the treatment of waste products from a polyphenol                   



               10The parties have stipulated that the relationships between           
          Madison’s general partner and the shareholders and officers of              
          PI, ECI, F&G, and RRI are the same as those described in Barlow             
          v. Commissioner, supra.                                                     




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