David and Shirley Singer - Page 17

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          to Mr. Bramnick", who in turn saw petitioner on a regular basis.            
          Bach recalled arguing with Bramnick because Bramnick wanted                 
          petitioner to purchase two limited partnership units at a cost of           
          $100,000, whereas Bach thought "one is enough".  Bond Richmond,             
          not Bach, was petitioner's offeree representative for Plymouth,             
          and that status entitled it to a commission equal to 10 percent             
          of petitioner's investment.                                                 
               In contrast to Bach's recollection of events, petitioner               
          claims that after Bach returned from Hyannis, he and his wife               
          discussed the Plymouth transaction with Bach at a dinner meeting.           
          According to petitioner, Bach informed them that he and a client            
          had visited PI and thought well of it, and that Bach was taking             
          another client, who petitioner knew was "a very successful                  
          attorney for some insurance company."  As petitioner recalls, "I            
          said if it was good enough for those fellows, it's * * * good               
          enough for me.  So that's when we made up our mind to do it."               
               Petitioners have no education or work experience in plastics           
          materials or plastics recycling.  They did not read the Plymouth            
          offering memorandum, see a Sentinel EPE recycler, or otherwise              
          investigate Plymouth or the Plastics Recycling transactions to              
          any extent.  Petitioners never made a profit in any year from               
          their investment in Plymouth.                                               
                                       OPINION                                        
               We have decided a large number of the Plastics Recycling               
          group of cases.  Provizer v. Commissioner, T.C. Memo. 1992-177,             




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