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was 10 years before the years in issue. As noted above, by the
time in issue PI was under new ownership in a new location, and
there is no reason to believe petitioner had any great knowledge
about the company or its business in 1982.
Second, Cohen and Feinberg claim to have a particularly
close relationship with Becker. Becker, however, testified that
he had a “very close relationship with the majority of [his]
clients.” Cohen and Feinberg were not singled out, and nothing
in the evidence demonstrates that Becker treated Cohen and
Feinberg any differently from any other client.11 Becker offered
the investments in SAB Foam and other similar partnerships to
many of his clients.
D. Miscellaneous
We dismiss petitioners’ contention that the allegedly
successful 1981 investment enjoyed by Cohen and Feinberg in SAB
Resource evidenced the reasonableness of the 1982 investment in
SAB Foam. SAB Resource limited partners received a royalty
payment within 3 months of their investment in addition to the
11 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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