Barry E. Moore and Deborah E. Moore - Page 35




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          view that Ms. Moore owned a 12-percent membership interest in the           
          LLC during the years in issue, 1999 and 2000.                               
                    2.  The Assignment and Assumption Agreement                       
               The assignment and assumption agreement does not set forth             
          an execution date.  Rather, it states that it “is made and                  
          entered into and effective as of the 1st day of January, 1997 by            
          and among * * * [the LLC members]”.                                         
               Petitioners argue that the execution date of the agreement             
          (alleged by petitioners, without dispute by respondent, to be               
          sometime during July 2000, when the agreement was entered into in           
          connection with the closing of the sale of the membership                   
          interests in the LLC to Surgicoe) is its effective date.  They              
          cite Georgia caselaw, which permits the introduction of parol               
          evidence to establish the actual date of execution, and they rely           
          upon both Georgia statutory law and caselaw, which permit                   
          equitable reformation of a contract in order to conform with the            
          true intent of the parties where there has been a mutual mistake            
          in the drafting of the contract.  Respondent disputes the                   
          applicability of both lines of authority.                                   
                    a.  Enforceability of the Effective Date Provision                
                    (1) Governing Principles of Georgia Law                           
               As noted supra, the assignment and assumption agreement                
          specifically states that it is to be “governed by and construed             
          in accordance with Georgia law.”  Under Georgia law, it is clear            







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