MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This matter is before the Court on petitioner's Motion for Summary Judgment. The issue for decision is whether petitioner is entitled to a judgment that a payment in the amount of $1,623,203 that he received from E.I. du Pont de Nemours & Co., Inc. (Dupont), in 1994 is excludable from his taxable income for that year pursuant to section 104(a)(2).
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