Petitioner was an investment banker at Smith Barney, Inc., prior to Travelers Group Inc.'s acquisition of Salomon Brothers Inc. and the subsequent merger of Salomon Brothers and Smith Barney. Following the merger, petitioner's duties at Salomon Smith Barney were reduced and he terminated his employment and joined CIBC Oppenheimer (Oppenheimer) pursuant to an employment agreement in June 1998. In April 1999,
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