Leon and Belle Atkind - Page 8

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            business and started a new business known as NBO.  NBO was a                                
            discount retail store chain which sold menswear.  Petitioner sold                           
            half of NBO to a Canadian business conglomerate in 1984, but he                             
            continued to run the business.  In 1988, petitioner sold his                                
            remaining interest in NBO for $25,000,000.                                                  
                  Petitioner was an active investor in the 1980's.  Between                             
            1980 and the date of trial, petitioner estimated that he invested                           
            approximately $16,000,000 in somewhere between 65 and 70                                    
            different enterprises.  Petitioner generally relied on his own                              
            judgment in evaluating proposed investments under $100,000; for                             
            larger investments he sought out professional guidance or                                   
            counsel.                                                                                    
                  Petitioner learned of the Hyannis investment through an                               
            acquaintance, Elliot I. Miller (Miller).  At that time, Miller                              
            was a practicing attorney who was experienced in tax matters and                            
            was employed as corporate counsel to PI.  Miller was a                                      
            shareholder in F & G in 1981.  He shared office space with                                  
            Raymond Grant (Grant) and Richard Roberts (Roberts) from 1982                               
            through 1984.  Grant was the 100-percent owner of the stock of                              
            ECI.  Miller represented Grant personally and Grant's clients who                           
            invested in other programs that Grant promoted.  Miller                                     
            recommended that petitioner speak with Roberts about proposed                               
            investments.                                                                                
                  Roberts was a businessman and the general partner in a                                
            number of limited partnerships that leased Sentinel EPE                                     
            recyclers, including Hyannis.  Roberts was also a 9-percent                                 



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