Estate of Paul C. Gribauskas - Page 15




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          section 2033, we find it unnecessary to probe whether the                   
          installments would also satisfy all of the specific criteria for            
          inclusion under section 2039.  Because an interest need not meet            
          each of the particular requirements of that section to be                   
          considered an annuity, the only arguments made in connection with           
          section 2039 that are directly relevant to the dispositive                  
          section 7520 issue are those concerning the meaning of “annuity”            
          as a stand-alone term.  Accordingly, we proceed to analysis of              
          these contentions, and we do so in the context of section 7520’s            
          use of the word.                                                            
               B.  Meaning of Annuity as Used in Section 7520                         
               We are now faced squarely with the question of what is meant           
          by the term “annuity” in section 7520.  The statute itself                  
          contains no definition beyond the phrase “any annuity, any                  
          interest for life or a term of years, or any remainder or                   
          reversionary interest”.  Sec. 7520(a).  The regulations under               
          section 7520, as in effect on December 3, 1994, are equally                 
          devoid of explicit guidance.  Furthermore, we are aware of no               
          cases offering a definition of the word in the context of section           
          7520’s use thereof.  In such circumstances, the general rule is             













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