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

Stephens (D) was convicted of fraud and was placed on five-years probation on the condition that he makes restitution to Raytheon in the amount of $1,000,000. That represented $530,000 in principal and $470,000 in interest. D was taxed on his receipt of the $530,000 in 1976. D did settle with Raytheon and turned over the $530,000 fund and executed a promissory note for $470,000 representing the interest. In an amended 1984 return, D claimed the $530,000 as a deduction.

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