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the Partnership transactions. An attorney representing one of
Tomasetti's client's supposedly did speak with some acquaintances
at PI.
Tomasetti did not attempt to market the Partnership
transactions himself. He thought they were very aggressive. He
fully expected an IRS challenge "because of the obvious tax
benefits in excess of the investment that were being achieved in
the first year". Tomasetti understood that the tax benefits
stemmed from the purported value of the Sentinel EPE recyclers,
and he did not believe it was prudent to invest in the
partnerships while relying upon the value of the recyclers as
represented in the offering materials. Tomasetti believed that
before investing, an interested party should have a strong
inclination that the Partnership transactions were economically
viable. Tomasetti thought that a substantial value for the
recyclers might be established in the future if the machines
performed well.
Frabotta understood that Omohundro questioned a few Boston
area law firms about PI and was told nothing that gave him
concern. Frabotta did not pursue an independent investigation of
the value of the Sentinel EPE recycler, nor did he ask anyone
else to investigate it. Frabotta discussed the value of the
recycler with Tomasetti and Omohundro only in passing. Frabotta
did not verify the price of resin; he did not inquire whether
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