BRIGHT, Senior Circuit Judge.
Allan and Gloria Molasky, husband and wife, appeal the tax court's decision assessing a $187,649.00 deficiency in income tax due for the 1981 tax year. On appeal, the Molaskys contend that the tax court erroneously upheld a $354,200 noncompetition provision in an agreement negotiated by Allan Molasky for the sale of a family business, a closely held corporation. The Molaskys further contest the tax court's conclusion that $324,000 of...
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