Harold E. Emmons and Anna Mae Emmons - Page 18

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          that petitioner received retirement distributions under section             
          4980A(e)(1) in the aggregate amount of $384,851.86.                         
               In order to give effect to our disposition of the disputed             
          issue, as well as respondent's concession and the parties'                  
          stipulation,                                                                


                                        Decision will be entered                      
                                        under Rule 155.                               
































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