In 1987, the individual plaintiffs, Donald and Carol Dolce, formed plaintiff D.D. Hamilton Textiles, Inc. (Hamilton). Hamilton did not retain a bookkeeper or an accountant until 1990 and, despite withholding money from employees for tax withholding purposes, failed to file any corporate tax returns prior to 1991. Similarly, the Dolces failed to file any personal tax returns after 1987.
In early 1990, plaintiffs approached Theodore Mate (whose estate is the defendant...
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