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where he held various positions in the corporate finance area,
including cost analyst, financial analyst, and eventually,
supervisor of profit analysis. In those positions, petitioner's
duties included analyzing the profitability of cars and looking
at the fixed costs to produce a new car. Petitioner left the
Ford Motor Co. in 1983 to start a financial planning firm.
Thereafter, petitioner became a certified financial planner and
has worked in the financial planning and investment advisory
business through the date of trial.
In 1978 or 1979, petitioner became acquainted with Louis
Cunningham, a financial planner and securities broker. Shortly
thereafter, petitioner began to invest in various mutual funds,
stocks, bonds, and variable annuities based on Cunningham's
suggestions and advice. Petitioner believed that all
investments presented to him by Cunningham had been reviewed and
placed on an approved list of investments by Cunningham's
brokerage firm, Mutual Service Corp. (MSC). In 1982, Cunningham
informed petitioner of an investment opportunity in the music
industry, specifically, the purchase of leasehold interests in
master recordings from the Southampton Music Co. (Southampton).
Cunningham earned a commission if petitioner decided to invest
in Southampton, and he encouraged petitioner to do so.
Petitioner could not recall whether Cunningham had indicated to
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