Impact Research Corporation, Joan C. Benz, Tax Matters Person - Page 16




                                       - 16 -                                         
          IRC to * * * [Systems] on or before March 31, 1985.”  At some               
          point, RIC became a party to an option agreement with Systems.              
               Under an agreement dated March 2, 1984, among IRC and its              
          shareholders, if Systems satisfied each of certain specified                
          conditions, then IRC’s shareholders were obligated to vote their            
          shares to approve the proposed merger or assets acquisition.  The           
          specified conditions in the March 2, 1984, IRC shareholders                 
          agreement are almost exactly the same as the specified conditions           
          in the above-described option agreement  If Systems did not                 
          satisfy the foregoing conditions, then the terms of any agreement           
          to merge or sell assets would be subject to negotiations.                   
               On or about March 26, 1985, Systems’ president asked that              
          the option expiration date be extended from March 31, 1985, to              
          May 31, 1985.  On or about March 29, 1985, the boards of                    
          directors of IRC and RIC refused the request for extension.                 
          D.  Mergers of IRC and RIC Into Systems                                     
               Contentious merger negotiations between Systems, IRC, and              
          RIC ensued after Systems’ option to buy the stock of IRC and RIC            
          expired on March 31, 1985.  The negotiations ultimately proved              
          successful and a merger occurred.                                           
                    _____________________________________________                     
               Both IRC and RIC were formed and operated primarily to                 
          furnish investment capital to Systems.  Neither IRC nor RIC spent           
          money in 1984 for the purpose of research or development in a               






Page:  Previous  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  Next

Last modified: May 25, 2011