In this case, the 9th Circuit affirmed a District Court's finding that amounts received by the taxpayer for personal goodwill from the sale of his dental practice should be treated as the sale of a corporate asset with a subsequent dividend distribution. In the same year the taxpayer incorporated his dental practice he entered into a covenant not to compete with the solely-owned corporation. The courts denied him capital gain treatment for proceeds from the sale allocated to personal goodwill because, as an employee of the corporation with a covenant not to compete, any goodwill generated from his professional work belonged to the corporation. The patient relationships were personal, but the economic value of those relationships did not belong to the taxpayer since he had conveyed them to the corporation. Howard v. U.S., 108 AFTR 2d 2011-XXXX (9th Cir.).