- 3 -
Texas counties, school districts, cities, and water districts
relating to collection of delinquent taxes.
PAYS was an S corporation. Petitioner held 100 shares in
PAYS, which was a 10-percent ownership interest. Petitioner’s
adjusted basis in his 100 shares was $92,039.
In 1994, petitioner became dissatisfied with PAYS’
management and decided to open his own law office and represent
certain PAYS clients. The officers of PAYS learned about
petitioner’s plan, discharged him from the firm, and threatened
to sue him for tortious interference with PAYS’ contracts with
its clients.
C. The Settlement Agreement
On December 23, 1994, petitioner and PAYS negotiated and
settled their dispute. Their agreement had five pages.
Petitioner and the remaining PAYS members initialed each page,
and signed the agreement on page 5. The first two pages of the
agreement (part 1) were entitled “AGREEMENT TO PURCHASE/SELL
SHARES”. The heading “ASSIGNMENT AND NON-COMPETITION” appears at
the top center of the third, fourth, and fifth pages of the
agreement (part 2). Centered beneath that title is “PAGE TWO” on
the fourth page and “PAGE THREE” on the fifth page. In part 2,
petitioner and PAYS resolved the threatened lawsuit related to
petitioner’s plan to take the Liberty County account with him.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011