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decedent’s IRA, and decedent was the primary beneficiary of
petitioner’s IRA. The four children of petitioner and decedent
were the contingent beneficiaries of both decedent’s IRA and
petitioner’s IRA.
At a time or times not disclosed by the record, decedent
purchased from Sun Life Assurance Company of Canada (Sun Life)
two annuity contracts, viz., the MFS Regatta Gold Fixed Annuity
(contract no. 76-7600-474212) and the MFS Regatta Gold
Fixed/Variable Annuity (contract no. 76-7600-574550), that were
in effect when he died on May 14, 2001.2 (We shall refer to
(1) decedent’s MFS Regatta Gold Fixed Annuity as decedent’s fixed
annuity contract, (2) decedent’s MFS Regatta Gold Fixed/Variable
Annuity as decedent’s fixed/variable annuity contract, and
(3) both such contracts collectively as decedent’s annuity
contracts.) Mr. Hopkins of A.G. Edwards was the plan administra-
tor for each of decedent’s annuity contracts.
In May or June 2001, Sun Life was notified that decedent had
died. Upon receiving notice of decedent’s death, Sun Life sent
to the plan administrator for each of decedent’s annuity con-
tracts (1) a letter dated June 18, 2001, with respect to dece-
dent’s fixed annuity contract (Sun Life’s June 18, 2001 letter)
and (2) a letter dated June 19, 2001, with respect to decedent’s
2It is not clear from the record whether decedent was re-
ceiving benefits before he died under the MFS Regatta Gold Fixed
Annuity and/or the MFS Regatta Gold Fixed/Variable Annuity.
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