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instruments executed by the trust would be to introduce a level
of artificiality warranted neither by the terms of the documents
nor by the attendant circumstances. Although petitioners urge
such a narrow perspective, a reading of all documents together as
evidencing a single, composite transaction appears to be more
consistent with the parties’ mind-sets at the time of the sale.
The purchase agreement makes reference to covenants from
“seller” and, through conscious addition by the buyers’ agent,
“officers”. The agreement further states that $650,000 is the
purchase price for the stock and “any covenant not to compete”
(emphasis added); it does not preclude apportionment to covenants
other than those stated therein. Moreover, the separate covenant
executed by petitioners then explicitly sets forth that it is an
agreement “regarding the sale of Little Rascals Child Care
Centers signed on the 30th of July, 1993.” It thus seems
reasonable to construe the separate document as carrying out the
“and officers” annotation in the purchase agreement.
In addition, the letter written by petitioners to the Shahs
only 2 weeks after the sale reveals that they did not view the
components of the transaction with the degree of isolation for
which they now contend. The letter reads: “As of August 13,
1993, Sharon has completed the training with Priti in accordance
with the requirements of our Purchase Agreement dated May 24,
1993, Section 15.” The use of “our Purchase Agreement”, combined
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