Daniel C. Greer and Winnie L. Greer - Page 4

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          not be determined in this case but should be determined                     
                                  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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