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on Becker. The Gollins never made a profit in any year from
their participation in SAB Reclamation. This was the only
investment Gollin made with Becker.
2. Myron and Patricia Fishbach
Petitioners Myron and Patricia Fishbach (the Fishbachs)
resided in Stamford, Connecticut, when their petition was filed.
Myron Fishbach (Fishbach) attended Syracuse University and later
earned a law degree at Fordham Law School in 1963. After briefly
working part time for a lawyer in Manhattan, Fishbach joined the
law firm of Pollan & Zimmer in Hicksville, Long Island. He
eventually became a named partner of that firm. Pollan & Zimmer
underwent several name changes: during taxable years 1981 and
1982 the firm was named Zimmer, Fishbach & Hertan. For
convenience, we shall refer to it, and its predecessors, as "ZFH"
or "the firm." ZFH concentrated in real estate, transactional
work, commercial matters, and some litigation. Over time the
firm acquired an office in New York City, although it continued
to maintain an office in Long Island.
Sometime in the late 1960's John Mosler (Mosler) of the
Mosler Safe Co. hired ZFH. Mosler had recently acquired a
substantial interest in a company called Bell Television (Bell),
and he wanted Fishbach to analyze the legal structure of Bell and
its affiliated companies. Touche, Ross was Bell's accounting
firm at the time, and Fishbach became acquainted with Becker at
meetings held at Bell. Fishbach found that Becker was well
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