Internal Revenue Service Department of the Treasury Washington, DC 20224 Number: 202630002 Release Date: 7/24/2026 Index Number: 72.00-00
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Third Party Communication: None Date of Communication: Not Applicable Person To Contact: --------------------- , ID No. ----------------- Telephone Number: -------------------- Refer Reply To: CC:FIP:B04 PLR - 104852-26 Date: April 28, 2026
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Taxpayer = ----------------------------------------------------------------------------------- ------------
Date = ----------------------
Dear ---------------- :
This letter revokes PLR 202426001 (PLR - 103975-24) issued to Taxpayer on April 3, 2024. This revocation applies retroactively.
In PLR 201424014 (PLR - 138374-13), the Internal Revenue Service (“Service”) issued two rulings with respect to a new term certain annuity option with variable payments (the “New Annuity Option”) that Taxpayer intended to offer with non-qualified deferred va riable annuity contracts. In PLR 202426001, the Service revoked the second ruling, that “[o]n and after the date an [o]wner elects the New Annuity Option, no amount will be includible in gross income before it is actually paid under the New Annuity Option .” This revocation applied prospectively only to contracts with applications signed after Date.
The Service has reconsidered its position and has determined that the position taken in PLR 201424014 was correct. Thus, the second ruling, that “[o]n and after the date an [o]wner elects the New Annuity Option, no amount will be includible in gross incom e
PLR - 104852-26
2 before it is actually paid under the New Annuity Option”, is reinstated by the revocation of PLR 202426001.
This letter ruling is directed only to the taxpayer who requested it. Section 6110(k)(3) of the Internal Revenue Code provides that a private letter ruling may not be used or cited as precedent. In accordance with the power of attorney on file with this office, we are sending a copy of this letter to the Taxpayer’s authorized representatives.
Sincerely,
Kathryn Sneade Branch Chief, Branch 4 Office of Associate Chief Counsel (Financial Institutions and Products)
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