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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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