Edward L. Walter and Jamie K. Walter - Page 16

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               Petitioners further argue that even if petitioner had been             
          authorized to pay the exercise price by the method set forth in             
          section 7.5(iii) of the 1995 Plan, such attempt was ineffective             
          because petitioner gave irrevocable instructions neither to                 
          Primus nor to Piper Jaffray.  We find petitioners’ arguments on             
          this point unavailing.  On July 14, 2000, Primus became obligated           
          to issue the shares, and Piper Jaffray became obligated to pay              
          for them, either by selling the shares or advancing funds on                
          margin.  Petitioner’s July 14, 2000, notice constitutes his                 
          unconditional acceptance of Primus’s offer under the stock option           
          grants and created a contract between Primus and petitioner for             
          the sale of the exercised shares of stock.  Petitioner could not            
          revoke or withdraw his acceptance of Primus’s offer.  Moreover,             
          petitioners have not shown that petitioner’s exercise was                   
          conditional or that he reserved the right to revoke the notice.             
               A “beneficial owner” is one who does not have legal title to           
          property but has rights in the property which are the normal                
          incidents of owning property.  Miller v. United States, 345 F.              
          Supp. 2d 1046, 1050 (N.D. Cal. 2004).  Such rights include the              
          right to receive dividends on and vote the shares, the right to             
          dispose of the shares as the beneficial owner sees fit, and the             
          right to use the shares as collateral.  See United States v.                
          Tuff, 359 F. Supp. 2d 1129, 1133 (W.D. Wash. 2005); Miller v.               
          United States, supra at 1050.  Another indication that a transfer           






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