This section contains the nature of the case and procedural background.

D underwrote public offerings of stock. D was tried under securities law for conspiracy and violations of the Securities Act of 1933. D was also charged with mail fraud and fraud. D was found guilty and fined $18,000 and sentenced to serve 4.5 years in prison. D paid $22,964.20 to defend himself. D claimed that as a deduction on his income taxes for 1956. The deduction was disallowed, and the Tax Court agreed. The Court of Appeals reversed en banc. The IRS appealed.

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