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if Mr. Langdon had begun to compete in year one, it seems to us
equally reasonable to increase the amount of loss that Bravo
would have experienced in the out years. See Buckley v.
Commissioner, T.C. Memo. 1994-470. Mr. Chouravong's assumption
that Mr. Langdon would not compete was based upon four additional
assumptions. Two are not supported at all by the record, and the
others are on shaky ground: (1) That Mr. Langdon would not
compete because he wanted to be free of the union; however, none
of the other distributorships were unionized, so this was clearly
not a deterrent. (2) That Mr. Langdon would have to work with
only microbreweries, which was not true. (3) That the consulting
agreement would be a deterrent. We agree that it would have some
effect but, for reasons stated above, it is not determinative.
(4) That Mr. Langdon’s age, time in business, and personal
reasons would deter him. Although one might suppose that a 71-
year-old person would want to retire, Mr. Langdon did not cite
that as a consideration in his testimony, which we found to be
credible. It is equally reasonable to believe that Mr. Langdon's
lengthy time in business might cause him to want to continue,
since he was obviously continuing to build and enjoy the business
at time of sale.
The "other personal reasons" presumably refers to the lack
of a male heir. Mr. Langdon did not name that as a reason, and,
in any event, it would not deter him from going to work for
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