The IRS challenged the allocation of purchase price of company to the covenant not to compete and intangible assets, and assessed additional income taxes due.
Langdon v. Commissioner
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8th Circuit Reallocates Value of Covenant Not to Compete to Intangible Assets Using a Nine-Factor Test
The parties to the sale of a beer distributorship allocated $1 million to the covenant not to compete and assigned no value to the company's intangible assets.