Annuities: Endowment and Life Insurance (Included v. Not Included in Gross Income)

ID:
Office:
UILC:
CCA_2011050611141650
---
72.00-00
Number: 201123031
Release Date: 6/10/2011
From: ---
Sent: Friday, May 06, 2011 11:14:25 AM
To: ---
Cc:
Subject: RE: PT attribution rules question
For purposes of section 4975(e)(6) of the Code family members only includes the following:
• The IRA owner’s (which in this case would be the fiduciary of the IRA under section
4975(e)(A) and section 4975(e)(3)) spouse
• Ancestors (Mom, Dad, Grandparents)
• Lineal Descendents (daughters, sons, grandchildren)
• Spouses of Lineal Descendents (son or daughter-in-law)
Therefore, in this case the taxpayer's brother in-law and parents in-law would not be considered family members under section 4975(e)(6) of the Code, because section 4975(e)(6) refers only to the spouse of a lineal descendent.