John T. Jorgl and Sharon Illi - Page 21




                                       - 21 -                                         
          with the fact that section 15 says “TRAINING:  Seller shall train           
          buyer”, indicates that petitioners saw themselves as material               
          participants in aspects of the sale other than their separate               
          agreement not to compete.  They also apparently recognized that,            
          legal obligations aside, only they could meaningfully act upon              
          certain provisions in the unique situation where a commercial               
          bank sells a child care center.  A similar inference can be drawn           
          from the fact that only petitioners, and not the trustee, were              
          involved in the meetings and negotiations with the Shahs which              
          preceded the signing of the purchase agreement.  Hence, in                  
          seeking to ascertain the parties’ intentions with respect to                
          price allocation, we likewise shall view the various participants           
          and documents as interrelated parts of an overall transaction.              
               Turning then to the substantive issue of mutual intent, we             
          conclude, again by reference to both written instruments and                
          attendant circumstances, that neither the documents themselves              
          nor the surrounding negotiations negate the existence of such               
          intent.  The language used (1) in the prospectus advertising                
          Little Rascals for sale, (2) in the purchase agreement, and (3)             
          in the separate covenant document is in each case consistent with           
          an understanding that a noncompetition agreement from petitioners           
          was to form a component of the sales price.  The prospectus                 
          describes the business as “established in 1980 by the current               
          owner, an architect”, makes no mention of the trust, states the             






Page:  Previous  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  Next

Last modified: May 25, 2011