Marco Deplano - Page 3

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          had been petitioner's accountant for approximately 4 years.  Mr.            
          Coscia was recommended to petitioner by a friend and coworker,              
          Herb Karlitz, an entertainment lawyer.  Petitioner relied heavily           
          on Mr. Coscia with respect to all financial matters and even                
          consulted him for help in selecting a health insurance plan.                
               Prior to 1983, and beginning in or around 1979 or 1980,                
          petitioner's investments had been exclusively in individual                 
          retirement accounts.  However, at some point in 1983, Mr. Coscia            
          approached petitioner with the idea of investing in a partnership           
          known as Ridge Energy Systems (Ridge Energy), which was in the              
          business of leasing energy management equipment from the Saxon              
          Energy Corporation (Saxon Energy).  Mr. Coscia recommended the              
          investment to petitioner, describing it as a "good idea" that               
          would be "very beneficial" to petitioner. Petitioner did not                
          independently investigate Ridge Energy, but instead relied on Mr.           
          Coscia's advice in making the investment.  Mr. Coscia assured him           
          that "there was a bank involved, a tax consultant involved, tax             
          specialist that made the whole thing completely kosher."  Mr.               
          Coscia also indicated to petitioner that there was profit                   
          potential in the investment.  Mr. Coscia advised him that he had            
          done "this kind of thing before, they were completely legal, and            
          there were benefits to be had, especially from a profit point of            
          view."  With respect to the payment schedule, Mr. Coscia                    
          indicated to petitioner that he would most likely receive profits           






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