OPINION.
RICE, Judge:
This proceeding involves a deficiency in income tax of $16,676.34 determined against petitioner, Julian Lentin, for the year 1946. The sole issue to be decided is whether the amount of $34,985.94 paid by petitioner in 1946 pursuant to a judgment entered against him by a United States District Court for willful violation of the Emergency Price Control Act of 1942,
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