8th Circuit Reallocates Value of Covenant Not to Compete to Intangible Assets Using a Nine-Factor Test

Business Valuation UpdateVol. 9 No. 5
Legal and Court Case Update
May 2003
5181 Beer and Ale
424810 Beer and Ale Merchant Wholesalers
federal taxation

Langdon v. Commissioner
59 Fed. Appx. 168, 2003 U.S. App. LEXIS 2714
February 14, 2003
Federal Court
8th Circuit
United States Court of Appeals
Per Curiam


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.

See Also

Langdon v. Commissioner

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.