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Upon returning from his visit to the PI plant in Hyannis,
Bach recalled speaking to petitioner about his observations, "but
not face-to-face. I know we spoke on the telephone." However,
Bach could not recall the substance of his communication with
petitioner or for how long they spoke on the phone. Petitioner
claims that he and his wife had a dinner meeting with Bach to
discuss his observations at PI. According to petitioner, Bach
informed him over dinner that Plymouth "was a wonderful deal,"
that another of Bach's clients purportedly "felt it was very
good," and that Bach intended to accompany another client to
Hyannis. Bach has no recollection of any such meeting.
We hold that petitioner's purported reliance on Bach was not
reasonable, not in good faith, nor based upon full disclosure.
Petitioner met and retained Bach to prepare his and his wife's
tax return in 1981. Bach characterized petitioners as an annual
tax account whom he saw infrequently. Bramnick was at least one
of petitioner's stock brokers and sometimes was an investment
adviser to petitioner. Bramnick introduced the Plastics
Recycling transactions and Plymouth to petitioner, as well as to
Bach. His firm, Bond Richmond, was the offeree representative
for petitioners and as such received a 10-percent commission on
petitioners' investment. Bach testified that he spoke mostly to
Bramnick with respect to Plymouth and that Bramnick saw
petitioner on a regular basis. However, notwithstanding
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