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Bros as a publicly traded company. By the time she left
employment at Maas Bros, petitioner had become a women's clothing
buyer for the store.
In her position as a buyer, before submitting orders to
manufacturers for clothing, petitioner examined and evaluated the
fabric and style of the clothing, the "selling history" and
history of profitability of the manufacturers based upon Maas
Bros' internal records.
Through management level associates at Maas Bros, petitioner
met Edward P. Russell (Russell) in the year 1977. Petitioner was
"impressed" with Russell and hired him as her tax return
preparer. Petitioner did not investigate Russell's professional
background or credentials, but he had a "good" reputation among
the managers. Russell prepared petitioner's Federal income tax
returns for the years 1977 through 1982.
Assisted by an attorney, petitioner in 1980 started her own
clothing business under the name, Deborah Kent's, Inc.
Petitioner prepared a business plan to submit to a bank in order
to obtain financing for Deborah Kent's, Inc.
In 1982, petitioner had "money in a money market account and
making minimal interest." Russell advised petitioner to reinvest
the money she had in the money market fund. Russell told
petitioner about the Republic Investment Partnership (Republic),
which held a partnership interest in Davenport Recycling
Associates (Davenport), a limited partnership. Russell explained
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