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There was one before [Plymouth], I think it was Empire,
and for some reason or other, I didn't jump at it and
then [Bramnick] called me, well, you missed it, because
they've got all the members they needed, they don't
have it--they may not have it again. Then they came
back a week or two later, I don't remember, but he
said, this thing is alive again * * *.
Petitioner did not recount any other conversations he may have
had with Bramnick or the substance of the broker's advice, if
any. Bramnick did not testify at the trial of this case.
Petitioner also discussed the Plastics Recycling
transactions with Martin Bach (Bach), a certified public
accountant (C.P.A.). Bach and petitioner were introduced
sometime in 1981 by Bramnick. At the time, petitioner was
looking for a tax return preparer. Petitioner retained Bach, and
Bach prepared petitioners' return for 1981 and for several years
thereafter.
Bach does not have any education or work experience in
engineering, plastics materials, or plastics recycling. He
graduated cum laude with a B.S. degree in accounting from Long
Island University in 1947. Three years later he became a
certified public accountant in New York State. After college,
Bach worked for several accounting firms before founding his own
practice in 1956, named Martin Bach & Co., P.C. (Bach & Co.).
Bach headed Bach & Co. for approximately 30 years until his
practice was taken over by another firm. Located in the Wall
Street area, Bach & Co. primarily serviced stock brokerage
houses. The firm represented clients before the Securities and
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