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for sales on these accounts after their transfer. Mr. Myers
received payments (known as equity payments) equal to the sum of
(1) the commissions credited to his account for orders entered on
the transferred accounts in the year before their transfer to
petitioner and (2) the commissions credited to petitioner's sales
account during 1970 from accounts transferred to him before 1970.
The equity payments were made in five equal annual installments
by way of offsetting debits and credits that Balfour posted to
the commission accounts that it maintained for petitioner and
Mr. Myers. Balfour did not include the debited commissions in
the commissions shown on petitioner's Forms W-2.
Sometime during 1989 or 1990, petitioner and Balfour entered
into a dispute over petitioner's commissions. The dispute
centered mainly on petitioner's accounts with AT&T, Prudential,
and the New York Giants and on a $281,773 commission that Balfour
had mistakenly paid petitioner during 1990. Petitioner also was
unhappy with the way Balfour manufactured and delivered its
products to customers in his sales territory.
During May 1991, petitioner talked to Robbins, Inc.
(Robbins), a competitor of Balfour, about leaving Balfour to work
for Robbins. One month later, on June 14, 1991, petitioner
resigned from Balfour and began working for Robbins as a sales
representative. Petitioner continued to work for Robbins through
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