- 21 - We view the record in the instant case in light of the foregoing. As 1984 began, Systems existed; IRC and RIC had not yet been created. Systems was developing interactive educational videodiscs and seeking to exploit the technology. Systems needed an additional $5-8 million to bring its videodiscs to market. IRC and RIC were created in 1984 through the efforts of Systems and Gould (Systems’ financial adviser); these efforts were motivated by Systems’ need for additional financing. Gould’s testimony makes it plain that IRC and RIC were created to meet Systems’ need for financing research that Systems wanted to do so that Systems could exploit interactive videodisc technology. Gould selected IRC’s and RIC’s potential shareholders in order to have these individuals contribute funds to IRC and RIC, in order to have IRC and RIC satisfy a portion of Systems’ financial needs. Gould was petitioners’ witness. Gould’s testimony completely negates any thought that IRC and RIC had the trade or business ideas and merely sought out Systems to do research in order to enable IRC and RIC to exploit new technology. A February 27, 1984, letter from John P. Clark (hereinafter sometimes referred to as Clark) to Systems’ president shows that Clark, too, understood that Systems was looking for a source of funds that Systems could use to advancePage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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