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unusual relationship with Stu”. Becker, however, testified that
he had a “very close relationship with the majority of [his]
clients.” Petitioner was not singled out, and nothing in the
evidence demonstrates that Becker treated petitioner any
differently from any other client.12 Becker offered the
investments in SAB Foam and other similar partnerships to many of
his clients.
Second, petitioners contend that Lewin “kept in touch” with
Miller over the 10 years after he left Miller & Summit. At
trial, however, Miller testified that after Lewin left the firm,
they “rarely” kept in touch. On this matter, we consider Miller
a more reliable witness than either petitioner or Lewin.
Miller’s testimony clearly shows that he had no special and close
relationship with Lewin during the years in issue. Petitioners
assert that Lewin also had an especially close relationship with
PI. Lewin testified, however, that he did not do any work for PI
after he left Miller & Summit, and that was 10 years before the
years in issue. As noted above, by the time in issue PI was
12 Becker testified:
there is nothing different that I told to one client
about the same issue than I told to another client.
There may have been things I said to one client that
might not have been said to another. But, if I spoke
about one issue while I might not have used precisely
the same words, in substance, * * * what was said to
one client on one matter, was said to every other
client when that matter was discussed.
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