Jeffrey I. and Roberta H. Stone - Page 21

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          of the offering memorandum, and a visit to Hyannis with Tomasetti           
          and Omohundro.  Tomasetti became involved at the behest of                  
          Frabotta and Omohundro; they paid him to review the offering                
          materials and visit PI with them.  Omohundro did not testify at             
          the trial; aside from visiting the PI plant in Hyannis, he                  
          purportedly phoned some legal contacts in Boston who knew of no             
          reason to be concerned about PI.  As for Finkle & Co., nothing in           
          the records indicates that they performed any due diligence, and            
          in 1983 they were providing services to either Northeast or                 
          Roberts.  See supra note 7.  Consequently, we must consider this            
          accounting firm part of the offering or promoting group.                    
               None of petitioners' supposed advisers had any background in           
          plastics or plastics recycling to help them analyze or assess the           
          recyclers, and the only persons they spoke to were insiders of              
          the Partnerships or PI personnel.  Neither Tomasetti nor Frabotta           
          made any inquiries regarding the value of the machine or sought             
          any independent investigation or third party appraisal.  The PI             
          personnel, insiders, and promoters they spoke to in Hyannis were            
          the ones petitioners ultimately relied upon for the value of the            
          Sentinel EPE recycler and the economic viability of the                     
          Partnership transactions.  See Vojticek v. Commissioner, T.C.               
          Memo. 1995-444, to the effect that advice from such persons "is             
          better classified as sales promotion."                                      
               Tomasetti understood that the tax benefits were generated by           
          the purported value of the recyclers and thought that "nobody               

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