Becker v. Commissioner of Internal Revenue Service

William Peeler Ewing

Practice Area:Tax

Outcome:The Tax Court ruled that none of the purchase price should be allocated to the noncompete covenant since the language in the contract clearly specified that the entire purchase price was for the stock.

Description:Stock Sale - Allocation of Purchase Price Issue. The parties to the stock sale disputed whether any of the purchase price should be allocated to a non-compete covenant. Mr. Ewing represented the seller and argued that none of the purchase price should be allocated to the non-compete covenant.