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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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