ROSEN, District Judge.
Petitioner/Appellant Louis A. Mitchell appeals a decision of the United States Tax Court disallowing a deduction of $755,172 which Mitchell had claimed as a business expense on his federal income tax return. This amount was a "restitution" payment made by Mitchell in order to keep stocks which he had obtained in violation of federal banking regulations. The IRS disallowed the claimed deduction finding that the amount paid was not deductible...
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