This matter involved a subsequent assessment by the I.R.S. of in excess of two (2) million dollars against the taxpayers for a 1986 transaction in which the taxpayers treated the gain on the sale of a corporation as capital gains. Thereafter, the buyer deducted a major portion of the selling price and designated same as payment for a non-competition obligation. The seller was a multi-billion dollar conglomerate known as W.P.P., Inc. This matter was handled in Appeals on Church Street in Manhattan by the then Chief of Appeals, Mr. Hagan. The matter was successfully negotiated and settled in Appeals for less than $50,000.00.