- 32 -
United States, supra at 430-431. Therefore, we conclude that 100
percent of the consideration paid by BHC to William Becker is
allocable to the purchase of William Becker’s stock, and none of
the consideration is allocable to the covenant not to compete.
In reaching our holdings, we have considered all arguments
and contentions made, and, to the extent not mentioned, we
conclude that they are moot, irrelevant, or without merit.
To reflect the foregoing and the concessions of the parties
in docket No. 6400-03,
Decision will be
entered for petitioners in
docket No. 13725-02, and
decision will be entered under
Rule 155 in docket No. 6400-
03.
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