Abe, Barb and Cindy are shareholders in a corporation, ABC, that provides computer consulting services. The business has been in existence for 4 years and Cindy is ready to move on and start a new venture. She requests to be bought out by the other two shareholders. After negotiations, they agree that Cindy will receive $300,000 for her stock and $50,000 for agreeing not to provide any computer consulting services for one year after separation (non-compete agreement). The $50,000 is the same amount that Cindy was guaranteed to receive as her annual salary. Can ABC deduct the $50,000 payment made to Cindy for the non-compete agreement?