You are a really really smart person and deserve that Obi Wan Kenobi picture by your name ! You are too smart to be a forum moderator here 🙂 

I've been absolutely mentally annihilated with a client's sale of a partnership interest. I sent the client the final return yesterday. Luckily, before we filed it, I realized that he may meet this NIIT exception, which you just summarized really well.   I've been researching this on the internet for a few hours, but you just managed to sum it up perfectly.  Its great that I happened to see your post 

Thanks for all your help. You rock !