- 22 - 1. Analysis of Annuity Characteristics We begin with a few comments on the relevance of the estate’s submissions regarding the characteristics of a typical annuity. While we do not dispute that the features cited may be widely present in commercially purchased annuity contracts, we point out that to the extent these elements are not also representative of so-called private annuities, they offer little insight into the nature of interests intended to be treated under the section 7520 tables. Section 7520(b) states that the section shall not apply for purposes “specified in regulations.” Section 20.7520-1, Estate Tax Regs., directs generally that annuities be valued in accordance with section 20.2031-7, Estate Tax Regs., and the tables therein. However, section 20.2031-7(b), Estate Tax Regs., expressly excepts commercial annuities from its operation, as follows: “The value of annuities issued by companies regularly engaged in their sale * * * is determined under � 20.2031-8.” Section 20.2031-8(a)(1), Estate Tax Regs., in turn provides that the value of such contracts “is established through the sale by that company of comparable contracts.” Since the State of Connecticut is not in the business of selling annuity contracts, we clarify that the attributes of a commercial annuity are relevant here only in so far as they parallel what would be found with respect to a private annuity.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
Last modified: May 25, 2011