Taxpayer Was Entitled to Nonrecognition of Gain Under Section 1035 on the Partial Exchange of an Annuity: Conway v. Commissioner
In Conway v. Commissioner, the Tax Court held that the transfer of a portion of an annuity contract into another annuity contract, with the original annuity surviving, qualifies under section 1035 as a nontaxable annuity-for-annuity exchange. The court reasoned that the transfer of funds from the old annuity account to the new account was direct...
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- Taxation Section