Dan and Patrick Zimbrick are the sole shareholders of Osprey Corporation. They are also officers of the corporation and members of the board of directors. In 2006, the Zimbricks entered into a repayment agreement with Osprey, which stipulated that they would reimburse the corporation for any salary that was subsequently disallowed as a deduction by the IRS. In late 2010, the IRS recharacterized $200,000 of Patrick’s 2007 salary and $150,000 of Dan’s 2007 salary as constructive dividends, disallowing Osprey’s compensation deduction for these amounts. Pursuant to the 2006 agreement, Dan and Patrick repaid the amount disallowed to Osprey in early 2011. How should the repayment by Dan and Patrick be treated for income tax purposes?