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D is a union official who, with another person, embezzled in excess of $738,000 during the years 1951 through 1954 from his employer-union and from an insurance company with which the union was doing business. D failed to report these amounts in his gross income in those years and was convicted for willfully attempting to evade the federal income tax due. D was convicted, and the conviction was affirmed. The Supreme Court granted certiorari.

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