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to a traditional IRA, qualified pension plan, or tax-shel-
tered annuity. * * *
On July 9, 2001, petitioner signed and dated Form W-4P for
her taxable year 2001 with respect to decedent’s fixed/variable
annuity contract (petitioner’s Form W-4P for fixed/variable
annuity contract). In that form, petitioner directed that no tax
was to be withheld from any distribution with respect to dece-
dent’s fixed/variable annuity contract. The instructions for
petitioner’s 2001 Form W-4P for decedent’s fixed/variable annuity
contract were identical to the instructions for petitioner’s 2001
Form W-4P for decedent’s fixed annuity contract.
On July 17, 2001, Sun Life received an undated letter from
petitioner with respect to decedent’s fixed annuity contract
(petitioner’s July 17, 2001 letter with respect to decedent’s
fixed annuity contract). In that letter, petitioner elected what
she referred to as a “lump sum death benefit payment” under
decedent’s fixed annuity contract and requested that Sun Life
“not withhold any taxes from this distribution.” Petitioner
enclosed with petitioner’s July 17, 2001 letter with respect to
decedent’s fixed annuity contract, inter alia, petitioner’s 2001
Form W-4P for decedent’s fixed annuity contract, including the
instructions to such form, a form entitled “ANNUITIZATION DATA
FORM” on which no information was contained and which had been
crossed out, and a form entitled “Direct Deposit Authorization”
in which petitioner directed Sun Life to deposit directly into
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Last modified: May 25, 2011