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dependent on any particular underlying asset, is not subject to
alteration as a result of external market forces, and does not
bear interest. Accordingly, while we see features which
distinguish the payment streams generated by each of the
nonannuity assets brought to our attention from the private
annuities reflected in case law, we find no such characteristics
weighing upon decedent’s right to the lottery installments.
Moreover, in probing what attributes might differentiate
some other form of payment from an annuity, we note a conspicuous
absence. The cases discussed above which declare certain payment
arrangements to be a private annuity never address the
contractual options available to the payee for taking advantage
of his or her right to the installments. Whether this right may
be transferred or assigned are elements which fail to enter into
the courts’ calculus. Likewise, of the stipulated factors that
apparently render note, leasehold, patent, and royalty payments
unique and individually valued, none reflects any concern with
the payee’s ability to manipulate the right to receive
installments. Additionally, because the estate so emphasizes the
concept of marketability, we observe as a parallel that the
parties provided by stipulation that notes come in a wide variety
of types including, among other things, nonassignable. Yet no
one could contend that lack of assignability converts a note into
some other form of asset. Hence, we are satisfied that such
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