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spouse receives additional annuity payments after the
participant's death.
On the basis, in part, of Silberstein’s treatment of the
plans as establishing subsidized joint and 100-percent survivor
annuities for Rozenblatt and Jakubowicz and their spouses,
petitioner made contributions to the plans in the total amounts
of $227,646, $226,794, and $226,794, respectively, for each of
the years 1987, 1988, and 1989.
On its Federal income tax returns for years ending
September 30, 1987, 1988, and 1989, petitioner claimed deductions
under section 404 for the above total respective contributions to
the plans in each year.
For the year ending September 30, 1990, petitioner did not
make any deductible contributions to the plans, and no deduction
with regard thereto was claimed on petitioner's 1990 Federal
income tax return.
On audit of petitioner for 1987, 1988, and 1989, respondent
treated Rozenblatt and Jakubowicz as receiving under the plans
only a reduced joint and 100-percent survivor annuity. The
present value of a reduced joint and 100-percent survivor annuity
equals the present value of a single life annuity for the life of
the participant (i.e., the value of a single life annuity for the
life of the participant is spread over the actuarial life
expectancies of the participant and the spouse).
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Last modified: May 25, 2011