- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011