Petitioners, Michael Schiraldi, III, and Carol Schiraldi, purchased an off-premises, retail liquor store from Mr. Schiraldi's father pursuant to a purchase agreement dated July 9, 1970 and an appended, undated rider which contained the seller's promise not to compete. From a total purchase price of $50,000, petitioners allocated $20,000 to furniture and fixtures, $5,000 to goodwill and $25,000 to...
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