Joseph D. & Elizabeth M. Dunne - Page 24




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          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.                                                        






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