the NCA left Andrews free to pursue a fresh start in any area other than ready-mix concrete. Significantly, Andrews had previously been involved in the real estate development business. Although it is unclear whether he maintained this business after filing his bankruptcy petition, there is no evidence that he could not have done so in order to obtain funds for his fresh start. 12 . As the dissenting opinion correctly notes, the terse reference to this issue in Matter of Walden, 12 F.3d 445 (5th Cir.1994), is dictum. 13 . See, e.g., In re McDaniel, 141 B.R. 438, 440 (Bankr.N.D.Fla.1992) (finding payments to former employee in exchange for non-competition agreement not made for services performed and thus not excluded from estate under § 541(a)(6)); In re Prince, 127 B.R. at 192 (<HOLDING>); In re Bluman, 125 B.R. 359, 363
holding consideration for covenant not to compete contained in purchase agreement for sale of business not tantamount to earnings from services performed postpetition holding that a claim arises from the purchase or sale of a security only if there is an allegation of fraud in the purchase sale or issuance of the  instrument holding an action for postpetition breach of an agreement to purchase property to be a core proceeding holding that agreement not to compete provided in conjunction with sale of business is agreement not to undermine value of good will that has been sold holding that a claim for breach of a provision in a merger agreement arises from the purchase or sale of the debtors securities