From 2015-2018, Paul Mann was employed by DJT, Inc. as a as a purchasing agent. DJT, Inc. sued Mann for fraud. The court ordered that Mann was to pay to DJT, Inc. damages in "the sum of $5,000,000, representing $4,500,000 in `kickbacks' illegally received by Mann from DJT, Inc.'s suppliers, and $500,000 in salary paid to Mann by DJT, Inc. while Mann was acting in a manner disloyal to his employer.Mann paid to DJT, Inc. $4,000,000 in 2019 and $1,000,000 In 2020. Is Mann entitled to IRC 1341 relief?