For purposes of this section, if section
126 property is disposed of less than 10 years after the date of receipt of payments excluded from gross income under section
126, the applicable percentage is 100 percent. If section
126 property is disposed of more than 10 years after such date, the applicable percentage is 100 percent reduced (but not below zero) by 10 percent for each year or part thereof in excess of 10 years such property was held after the date of receipt of the payments.