- 15 - 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 isPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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