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not be determined in this case but should be determined
separately.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly. The stipulation of facts and the attached exhibits
are incorporated herein. Petitioners resided in Lexington,
Kentucky, at the time they filed the petition in this case.
Petitioner husband received a bachelor of science degree in
chemical engineering from the University of Kentucky in 1967.
Petitioner wife graduated from Louisiana State University with a
bachelor of arts degree in music in 1969. She also received a
master’s degree in music education from Marshall University in
1973. Petitioners were married in 1967.
Petitioner husband, referred to hereinafter as Mr. Greer,
was employed in 1967 as a chemical engineer for Exxon Chemical
Co. From 1969 until July 1993, Mr. Greer was employed by Ashland
Oil Co., Inc., and its subsidiaries (AOI). From 1975 to 1980,
Mr. Greer was a key assistant to the executive vice president of
AOI. During that period, Mr. Greer participated in AOI’s
executive development program. He also attended a petroleum
economics program at Northwestern University and took an
accounting course for nonfinancial managers at Ohio State
University. In 1982, Mr. Greer was an executive in the part of
AOI’s business characterized as Ashland Development. In that
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