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Clyde had work for many years as the chief executive of Red Industries, and had also been a major shareholder. Clyde and the company had a falling out, and Clyde was terminated. Clyde and Red executed a document under which Clyde stock on Red would be redeemed and Clyde would agree not to compete against Red in its geographic service area. After negotiations, Clyde agree to surrender his Red stock in exchange for $600,000.Clyde basis in his shares was $143,000, and he had held the shares for 17 years. The agreement made no explicit allocation of any of the $600,000to Clyde's agreement not to compete against Red. How should Clyde treat the $600,000 payment on his 2009 tax return?

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