David and Shirley Singer - Page 28

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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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