Fred and Mary Gillette - Page 4

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          presented no new facts or contentions.  Accordingly, we sustain             
          respondent's determination that the $155,888 is not excludable              
          under section 104(a)(2).                                                    
               We have considered all other arguments made by the parties             
          and found them to be either irrelevant or without merit.                    
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          
































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