OPINION
RUWE, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable years 1981 and 1982 in the respective amounts of $89,574.58 and $264,854.92. The issues for decision are whether distributions which Foley Equipment, Co. (Equipment) made to petitioner during 1981 and 1982 may be recharacterized as nontaxable repayments of commissions paid in error, rather than actual distributions...
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