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the application of that section. Sec. 20.7520-3, Estate Tax
Regs. The estate has raised none of these exceptions, and they
will not be further addressed.
Section 20.2031-7, Estate Tax Regs., entitled “Valuation of
annuities, interests for life or term of years, and remainder or
reversionary interests”, reads in part:
(a) In general.--Except as otherwise provided in
paragraph (b) of this section and sec. 20.7520-3(b)
(pertaining to certain limitations on the use of
prescribed tables), the fair market value of annuities,
life estates, terms of years, remainders, and
reversionary interests for estates of decedents is the
present value of such interests, determined under
paragraph (d) of this section. The regulations in this
and in related sections provide tables with standard
actuarial factors and examples that illustrate how to
use the tables to compute the present value of ordinary
annuity, life, and remainder interests in property.
These sections also refer to standard and special
actuarial factors that may be necessary to compute the
present value of similar interests in more unusual fact
situations.
(b) Commercial annuities and insurance
contracts.--The value of annuities issued by companies
regularly engaged in their sale, and of insurance
policies on the lives of persons other than the
decedent, is determined under sec. 20.2031-8. * * *
The referenced section 20.2031-8, Estate Tax Regs., then states,
as relevant here: “The value of a contract for the payment of an
annuity, or an insurance policy on the life of a person other
than the decedent, issued by a company regularly engaged in the
selling of contracts of that character is established through the
sale by that company of comparable contracts.” Sec. 20.2031-
8(a)(1), Estate Tax Regs.
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