MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated February 10, 1999, respondent determined a deficiency of $218,903 relating to petitioners' 1995 Federal income tax. All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issue for decision is whether petitioners are entitled, pursuant to section 104(a)(2), to exclude...
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