- 17 -
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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