Frontier Chevrolet Co. - Page 13




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          lacks merit.                                                                
               We find that the noncompetition agreement was entered into             
          in connection with an acquisition of an interest in a trade or              
          business.  Therefore, we hold that petitioner must amortize the             
          noncompetition agreement payments to Roundtree and Mr. Stinson              
          over 15 years pursuant to section 197.                                      

                                                  Decision will be entered            
                                             under Rule 155.                          

































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Last modified: May 25, 2011