- 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