- 24 - to Mr. Marcus.4 The parties do not dispute that the settlement agreement, unlike the Inverness agreement, was a valid and legally enforceable contract under which Mr. Dunne agreed to sell his FRC stock. However, because the settlement agreement did not terminate Mr. Dunne’s interest in FRC until the settlement date, which in 1997 was still some unspecified date in the future, we must consider whether Mr. Marcus nonetheless possessed substantially all of the accouterments of ownership by May 8, 1997. The key provisions of the settlement agreement are that in exchange for his stock Mr. Dunne would receive the book value of FRC, set at $175,000, and half of the profit from the halon contract. Mr. Dunne’s FRC stock would be held in escrow until he received his share of the halon contract and the book value of his stock. The settlement agreement also provided that Mr. Dunne would have no shareholder or director rights after the settlement date, which was to be the date of signing a memorializing document anticipated to be no later than May 16, 1997. Respondent argues that because the settlement agreement expressly provided that Mr. Dunne would hold no shareholder 4 While respondent argues that petitioners have abandoned this alternative argument because they did not argue it in their posttrial brief, we believe that it is in the best interest of justice to consider this alternative argument. During the trial, we raised the issue of whether it was appropriate to consider the settlement date as the date of sale, and respondent addressed this issue on brief.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 NextLast modified: March 27, 2008