- 4 -
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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Last modified: May 25, 2011