United States Court of Appeals
Langdon and BDC had a deficiency in their income taxes for the 1992 tax year. Langdon and BDC challenged the Commissioner’s determination and filed an action in the United States Tax Court. 1 The tax court ruled that Langdon’s covenant not to compete with Bravo was not worth $1 million. The bulk of the $1 million covenant,
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United States Court of Appeals
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