{"meta":{"key":"r036--pass-01","task":"R036","title":"Federal life-insurance borrowing and modified-endowment tax treatment","parent_title":"Using assets or other borrowing","edition":"pass-01","path":"/research/r036--pass-01/","kind":"split_pass","category":"subject","role":"primary_area","area_numbers":[36],"groups":["ways-forward"],"date":"2026-10-28","tables":14,"claims":113,"sources":24,"review_status":"scoped_coordinator_review_completed_with_material_primary_access_currentness_application_holds","review_complete":true,"sha256":"c8c6ba91e08996a97813c594c5c7ec4aa4503ecfee430d0f8d7fabadfcdd977c","headings":["1. Research record, authority status, and source register","Source table","2. Substantive findings and atomic claim register","A. Contract qualification and distinct measurements","B. Modified endowment contract: definition, testing, changes, aggregation, and transitions","C. Receipt, borrowing, distributions, investment recovery, and later events","D. Additional tax and annuity boundaries","E. Interest and deduction limitations","F. Exchanges and death-benefit boundaries","G. Reporting and withholding are separate from substantive liability","3. Provision-specific comparison","4. Substantive qualitative branches","5. Wholly blank evidence and audit worksheet","6. Calculation and illustration decision","7. Granular coverage and crosswalk","8. Source-read and failure log","9. Explicit gaps and limits","10. Researcher self-check — not independent review"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-6","actual_mode":"Pro","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"R036/pass-01","facets":{"geography":["us","us-federal"],"debt_type":["tax","life_insurance_loans"],"stage":[],"subject":["tax-cancellation"]},"scope":"SettleADebt R036 PASS-01 — FIRST FOCUSED A036 COMPONENT: US FEDERAL INCOME-TAX TREATMENT OF LOANS, ASSIGNMENTS/PLEDGES AND DISTRIBUTIONS INVOLVING LIFE-INSURANCE CONTRACTS, INCLUDING THE MODIFIED-ENDOWMENT-CONTRACT BOUNDARY. A036 also covers savings/asset sales, family help, home equity, retirement loans/withdrawals and insurance loans. Independently investigate ONLY the generic published federal statutory/regulatory tax framework needed for the life-insurance-loan component. The separate retirement-plan-loan report is not a foundation and must not be regenerated. No actual or invented person, insurer, lender, provider, entity, policy, account, borrower, property, case-record, roster or identifying-entry query. Generic contract roles, abstract symbols and entirely blank audit fields only.","pending_corrections":0},"markdown":"# R036 PASS-01 — A036 life-insurance-loan component\n\n**The controlling distinction is conditional.** Section 72(e)(5)(C) generally preserves the special treatment of nonannuity amounts under qualifying life-insurance contracts, including turning off §72(e)(4)(A)’s loan-and-pledge deeming rule. Section 72(e)(10) turns that rule back on for a contract meeting the actual modified-endowment-contract definition in §7702A, and extends it to **any person**. Neither provision establishes that every contract called “permanent insurance,” every loan, or every outstanding balance has the same treatment. Complete surrender, benefit reductions, contract qualification, issue and change dates, prior distributions, and investment in the contract require separate analysis. **Claims C002–C005, C035–C070 below provide the operative conditions.** [uscode.house.gov+1](https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com)\n\n## 1. Research record, authority status, and source register\n\n**Access:** October 27, 2026, America/Los_Angeles. The session clock was checked at October 28, 2026, 01:39:11 UTC, corresponding to October 27, 2026, 18:39:11 in Los Angeles. The subsequent public-source reads occurred during that same Los Angeles date.\n\n**Jurisdiction:** United States federal income tax throughout. References in federal statutes to applicable insurance law, state filings, or insurance standards are predicates; they do not establish compliance with any particular nonfederal law.\n\n**Currentness limit:** The retrieved OLRC pages carry the individual currency statements recorded below. OLRC’s general currency page and the inspected 2026 classification table extended through Public Law 119-134, October 20, 2026. The inspected Title 26 classification entries did not identify a 2026 amendment to §§72, 264, 7702, or 7702A. This is a targeted compilation-and-classification check, **not a complete session-law, regulatory-history, or judicial-status audit through the access date**. [US Code+1](https://uscode.house.gov/currency.html?utm_source=chatgpt.com)\n\n**Reference convention:** In the remaining tables, S001 means R036-P1-S001, and C001 means R036-P1-C001. Those references resolve to the source and atomic-claim rows below. HTML sources have no printed-page or PDF-index coordinate. PDF page indexes are expressly zero-based.\n\n### Source table\n\n| Source ID | Issuer, instrument, and complete literal HTTPS URL | Version, legal status, and effectiveness | Actual read bounds, precise pinpoints, and limits |\n| --- | --- | --- | --- |\n| **R036-P1-S001** | Congress; OLRC, **26 U.S.C. §72, Annuities; certain proceeds of endowment and life insurance contracts**. [https://uscode.house.gov/us/usc/119-124/t26/s72/](https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-124, October 15, 2026**. Statute as amended; applicable historical and transition provisions must be selected separately. | Read complete **(a)–(c), (e)(1)–(12), (f), (g), (h), (j), (l), (m)(7), (q), (u), and (v)**; selected **(p)(1), (p)(5), and (s)(6)(B)** for boundaries only. Read material amendment/effective-date notes concerning 1982, 1984, 1986, 1988–1989, 1996, 2006, 2010, and the relevant 2022 annuity amendment. **Not a whole-§72 or whole-notes read.** [uscode.house.gov+2](https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com) |\n| **R036-P1-S002** | Congress; OLRC, **26 U.S.C. §7702A, Modified endowment contract defined**. [https://uscode.house.gov/us/usc/119-121/t26/s7702A/](https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-121, October 9, 2026**. Added by P.L. 100-647, §5012(c), November 10, 1988; substantive applicability generally begins with contracts entered into on or after June 21, 1988, subject to the reproduced transitions. | **Whole section (a)–(e), source credit, amendments, effective-date notes, and 2002 construction note read.** Particularly §§7702A(a), (c)(2)–(6), (d), (e), and P.L. 100-647 §5012(e), as amended. [uscode.house.gov](https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com) |\n| **R036-P1-S003** | Congress; OLRC, **26 U.S.C. §7702, Life insurance contract defined**. [https://uscode.house.gov/us/usc/119-124/t26/s7702/](https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-124, October 15, 2026**. Added July 18, 1984. The 2020 interest-assumption amendments apply to contracts issued **after December 31, 2020**. Other applicability rules are detailed below. | **Whole section (a)–(k), source credit, amendments, and displayed notes read.** Material pinpoints: (b)–(f) qualification and measurements; (f)(7) benefit-reduction recapture; (g) failure; (i)–(j) special categories; P.L. 98-369 §221(d), P.L. 116-260 div. EE §205(e). [uscode.house.gov+1](https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com) |\n| **R036-P1-S004** | Congress; OLRC, **26 U.S.C. §264, Certain amounts paid in connection with insurance contracts**. [https://uscode.house.gov/us/usc/119-134/t26/s264/](https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. Current statutory body includes separate purchase-date rules and historical transition provisions. | **Whole section (a)–(f), source credit, amendments, and displayed notes read.** §§264(a)(2)–(4), (c)–(f), and P.L. 104-191 §501(c)–(d) are material. Full business-deduction application remains excluded. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com) |\n| **R036-P1-S005** | Congress; OLRC, **26 U.S.C. §163, Interest**. [https://uscode.house.gov/us/usc/119-134/t26/s163/](https://uscode.house.gov/us/usc/119-134/t26/s163/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. | Selected **(a), (h)(1), and (h)(2)** read for the separate deduction gate. Not a complete §163, investment-interest, business-interest, residence-interest, or other personal-interest-exception analysis. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s163/?utm_source=chatgpt.com) |\n| **R036-P1-S006** | Congress; OLRC, **26 U.S.C. §101, Certain death benefits**. [https://uscode.house.gov/us/usc/119-134/t26/s101/](https://uscode.house.gov/us/usc/119-134/t26/s101/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. | Read **(a)–(f)**, with (f)’s concluding clauses separately completed. Used (a), (c), and (d) only as death-benefit boundaries; read **(f) completely** for pre-1985 flexible-premium predicates. Read P.L. 105-34 §1084(d) note concerning post-June 8, 1997 contracts and material changes. Not a complete death-benefit or employer-owned-insurance analysis. [uscode.house.gov+2](https://uscode.house.gov/us/usc/119-134/t26/s101/?utm_source=chatgpt.com) |\n| **R036-P1-S007** | Congress; OLRC, **26 U.S.C. §1035, Certain exchanges of insurance policies**. [https://uscode.house.gov/us/usc/119-134/t26/s1035/](https://uscode.house.gov/us/usc/119-134/t26/s1035/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. Long-term-care exchange amendments apply to exchanges after December 31, 2009. | **Whole (a)–(d), source/amendment/effective-date notes read.** Foreign-person regulatory limitation identified but not developed. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s1035/?utm_source=chatgpt.com) |\n| **R036-P1-S008** | Congress; OLRC, **26 U.S.C. §1031, Exchange of real property held for productive use or investment**, incorporated provisions. [https://uscode.house.gov/us/usc/119-134/t26/s1031/](https://uscode.house.gov/us/usc/119-134/t26/s1031/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. | Read complete **(b)–(d)** because §1035(d) incorporates them. **No real-estate exchange timing rules applied.** Not a whole-section/history read. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s1031/?utm_source=chatgpt.com) |\n| **R036-P1-S009** | Congress; OLRC, **26 U.S.C. §357, Assumption of liability**, incorporated definition. [https://uscode.house.gov/us/usc/119-134/t26/s357/](https://uscode.house.gov/us/usc/119-134/t26/s357/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. | Read complete **(d)(1)–(3)** for the liability-assumption definition incorporated by §1031(d). Corporate-transfer treatment and complete historical applicability not investigated. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s357/?utm_source=chatgpt.com) |\n| **R036-P1-S010** | Congress; OLRC, **26 U.S.C. §817, Treatment of variable contracts**. [https://uscode.house.gov/us/usc/119-134/t26/s817/](https://uscode.house.gov/us/usc/119-134/t26/s817/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. | Read complete **(d) and (h)** for variable-contract and diversification boundaries. **Treas. Reg. §1.817-5 and underlying asset qualification were not comprehensively investigated.** [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s817/?utm_source=chatgpt.com) |\n| **R036-P1-S011** | Congress; OLRC, **26 U.S.C. §7702B, Treatment of qualified long-term care insurance**. [https://uscode.house.gov/us/usc/119-134/t26/s7702B/](https://uscode.house.gov/us/usc/119-134/t26/s7702B/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. Includes 1996 enactment and 2006 coordination notes. | Read **(b), (c), (e), (g)** and material displayed notes, including **P.L. 104-191 §321(f)(4)**. No medical-status determination, state-law qualification investigation, or complete reading of incorporated insurance model standards. [uscode.house.gov+1](https://uscode.house.gov/us/usc/119-134/t26/s7702B/?utm_source=chatgpt.com) |\n| **R036-P1-S012** | Treasury; eCFR, **Treas. Reg. §1.72-2, Applicability of section 72**. [https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2](https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2) | Codified final regulation; retrieved eCFR status through **October 22, 2026**. Source history includes T.D. 6500, November 26, 1960; T.D. 6497, October 20, 1960; T.D. 6885, June 2, 1966. | Read **(a)(1)–(2), (b)(1)–(3)** and source note. Used for annuity/nonannuity boundary, subject to later statutes. Original Treasury-decision preambles and all historical effectiveness provisions not read. [ecfr.gov+1](https://www.ecfr.gov/current/title-26/section-1.72-2?utm_source=chatgpt.com) |\n| **R036-P1-S013** | Treasury; eCFR, **Treas. Reg. §1.72-11, Amounts not received as annuity payments**. [https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11](https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11) | Codified final regulation; retrieved status through **October 16, 2026**. Source history includes T.D. 6500, November 26, 1960; T.D. 6885, June 2, 1966; T.D. 8115, December 19, 1986. | **Whole (a)–(h) and source note read.** Material surrender provision **(d)(1)–(2)**. Historical caps and obsolete cross-references were not treated as overriding amended §72. Full original-decision effectiveness audit not performed. [ecfr.gov+2](https://www.ecfr.gov/current/title-26/section-1.72-11?utm_source=chatgpt.com) |\n| **R036-P1-S014** | Treasury, **Treas. Reg. §1.7702-2, Attained age of the insured under a life insurance contract**; T.D. 9287. [https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2](https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2). Same instrument in [https://www.irs.gov/irb/2006-46_IRB](https://www.irs.gov/irb/2006-46_IRB?utm_source=chatgpt.com). | Final T.D. 9287, **September 13, 2006**, 71 FR 53970; effective that day, with distinct contract applicability under paragraph (f). First retrieved eCFR snapshot through **October 13, 2026**. IRB publication November 13, 2006. | **Whole regulation (a)–(f), including examples and applicability, read.** Selected T.D. preamble/version material read in IRB, not the whole bulletin. These formats are one instrument, not independent corroboration. [ecfr.gov+1](https://www.ecfr.gov/current/title-26/section-1.7702-2?utm_source=chatgpt.com) |\n| **R036-P1-S015** | Treasury; eCFR, **Treas. Reg. §1.1035-1, Certain exchanges of insurance policies**. [https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1](https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1) | Codified final regulation; retrieved status through **October 23, 2026**. **Original issuance/effective date not verified in the retrieved section.** | Whole section text read. Same-insured/same-obligee and money/other-property provisions used. Its older exchange-category wording was read with current §1035, including later long-term-care amendments. [ecfr.gov](https://www.ecfr.gov/current/title-26/section-1.1035-1?utm_source=chatgpt.com) |\n| **R036-P1-S016** | IRS, **Rev. Rul. 2009-13**. [https://www.irs.gov/pub/irs-drop/rr-09-13.pdf](https://www.irs.gov/pub/irs-drop/rr-09-13.pdf?utm_source=chatgpt.com). Published in [https://www.irs.gov/irb/2009-21_IRB](https://www.irs.gov/irb/2009-21_IRB?utm_source=chatgpt.com). | Published IRS interpretation, **2009-21 I.R.B. 1029, May 26, 2009**. Modified by S017; not relied on as an unmodified instrument. | **All 12 PDF pages read as parsed text, indexes 0–11.** Surrender analysis: printed **pp. 3–5 / indexes 2–4**; holding 1: printed **p. 11 / index 10**. Its surrender situation has no outstanding loan or prior withdrawals. No PDF-pixel inspection claimed; no case opinions investigated. [irs.gov+1](https://www.irs.gov/pub/irs-drop/rr-09-13.pdf?utm_source=chatgpt.com) |\n| **R036-P1-S017** | IRS, **Rev. Rul. 2020-05**. [https://www.irs.gov/pub/irs-drop/rr-20-05.pdf](https://www.irs.gov/pub/irs-drop/rr-20-05.pdf?utm_source=chatgpt.com). Published in [https://www.irs.gov/irb/2020-09_IRB](https://www.irs.gov/irb/2020-09_IRB?utm_source=chatgpt.com). | Published IRS interpretation, **2020-9 I.R.B. 454, February 24, 2020**. Its stated effective date is transactions on or after August 26, 2009. | **All six PDF pages read as parsed text, indexes 0–5.** Material modification discussion printed **pp. 4–5 / indexes 3–4**; effect on other documents and effective date printed **p. 6 / index 5**. Used to establish S016’s modified status, not to regenerate an asset-sale component. No pixel inspection. [irs.gov+1](https://www.irs.gov/pub/irs-drop/rr-20-05.pdf?utm_source=chatgpt.com) |\n| **R036-P1-S018** | IRS, **Publication 525 (2025), Taxable and Nontaxable Income**. [https://www.irs.gov/publications/p525](https://www.irs.gov/publications/p525?utm_source=chatgpt.com) | Public explanatory publication, **2025 version**; exact original issuance/revision day not established. It is not a statute or final regulation. | Selected “Life Insurance Proceeds,” especially complete **“Surrender of policy for cash”** paragraph, read. Not the whole publication. Its simplified treatment of unrepaid loans is qualified below; it does not establish all lapse scenarios. [Internal Revenue Service](https://www.irs.gov/publications/p525?utm_source=chatgpt.com) |\n| **R036-P1-S019** | IRS, **Instructions for Forms 1099-R and 5498 (2026)**. [https://www.irs.gov/instructions/i1099r](https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com) | Public reporting instructions, **2026 version**; exact issuance/revision day not established. A tax-year heading is not a substantive effective-date finding. | Read material body: life-insurance/annuity/endowment reporting; §1035 exchanges; boxes **1, 2a, 2b, 4, 5, 7a**; relevant distribution-code entries and notes. **Not whole instructions; no blank-form PDF or pixels inspected; no form completed.** The §72(v) periodic-payment coding issue is explicitly unresolved below. [Internal Revenue Service+3](https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com) |\n| **R036-P1-S020** | Congress; OLRC, **26 U.S.C. §31, Tax withheld on wages**, incorporated credit rule. [https://uscode.house.gov/us/usc/119-134/t26/s31/](https://uscode.house.gov/us/usc/119-134/t26/s31/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. | Complete **(a)(1)–(2)** read for crediting chapter 24 withholding. Not a return or tax-payment calculation. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s31/?utm_source=chatgpt.com) |\n| **R036-P1-S021** | Congress; OLRC, **26 U.S.C. §6047, Returns relating to certain trusts and annuity plans**. [https://uscode.house.gov/us/usc/119-134/t26/s6047/](https://uscode.house.gov/us/usc/119-134/t26/s6047/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. | Selected complete **(d)(1)–(2), (g), (h)** and relevant source/amendment notes read. §6047(d)’s issuer reporting rule and §6050Y coordination identified; complete reporting obligations excluded. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s6047/?utm_source=chatgpt.com) |\n| **R036-P1-S022** | Congress; OLRC, **26 U.S.C. §3405, Special rules for pensions, annuities, and certain other deferred income**. [https://uscode.house.gov/us/usc/119-134/t26/s3405/](https://uscode.house.gov/us/usc/119-134/t26/s3405/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-134, October 20, 2026**. | Read **(a)–(e)(13)**. Relied on **(d), (e)(1), (e)(6), and (e)(8)** to distinguish reporting/withholding classification, payor duties, cash limitations, and substantive income treatment. No full withholding determination or rate calculation. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s3405/?utm_source=chatgpt.com) |\n| **R036-P1-S023** | OLRC, **Currency and Updating; Classification Tables; 2026 classification table**. [https://uscode.house.gov/currency.html](https://uscode.house.gov/currency.html?utm_source=chatgpt.com); [https://uscode.house.gov/classification/tables.html](https://uscode.house.gov/classification/tables.html?utm_source=chatgpt.com); [https://uscode.house.gov/classification/tbl119cd_2nd.html](https://uscode.house.gov/classification/tbl119cd_2nd.html?utm_source=chatgpt.com) | Publisher currency and classification metadata; **not substantive tax authority**. | Currency and table-explanation pages read; 2026 table header and **entire Title 26 block** read. Not the entire classification table or a full session-law audit. [US Code+2](https://uscode.house.gov/currency.html?utm_source=chatgpt.com) |\n| **R036-P1-S024** | Congress; OLRC, **26 U.S.C. §807 notes**, P.L. 115-97 §13517(c). [https://uscode.house.gov/us/usc/119-124/t26/s807/](https://uscode.house.gov/us/usc/119-124/t26/s807/?utm_source=chatgpt.com) | Retrieved text through **P.L. 119-124, October 15, 2026**. Enactment December 22, 2017; specified amendments apply to taxable years beginning after December 31, 2017. | Read complete **§13517(c)(1)–(3)** effective-date, transition, and transition-relief note. Not whole §807. The reserve transition was not imported into policyholder loan taxation. [uscode.house.gov](https://uscode.house.gov/us/usc/119-124/t26/s807/?utm_source=chatgpt.com) |\n\n## 2. Substantive findings and atomic claim register\n\nThe following tables are the substantive findings. Each row states a conditional proposition, its exact authority, and its application limit. No row classifies an actual contract or establishes an actual amount.\n\n### A. Contract qualification and distinct measurements\n\n| Claim ID | Supported proposition and consequential conditions | Exact authority and scope |\n| --- | --- | --- |\n| **R036-P1-C001** | The retrieved statutory versions and targeted classification check support the version statements in the source register. They do not establish that every later enactment, judicial development, or original regulatory effective-date instrument was audited. | **S001–S024**, their stated currency/read bounds; **S023**, currency page and 2026 Title 26 classification block. |\n| **R036-P1-C002** | Under the generally applicable §7702 definition, a life-insurance contract must be life insurance under applicable law **and** satisfy either the cash-value-accumulation test or both the guideline-premium requirements and cash-value corridor. A product label does not establish these elements. The church-plan exception is separately addressed in C027. | **S003, §7702(a)(1)–(2), (j)**. [uscode.house.gov](https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com) |\n| **R036-P1-C003** | **For §7702**, “cash surrender value” means cash value determined without regard to a surrender charge, policy loan, or reasonable termination dividends. Thus this statutory measurement can differ from cash deliverable after charges and debt offsets. | **S003, §7702(f)(2)(A)**. This is a section-specific definition, not a universal definition for every tax provision or contract. |\n| **R036-P1-C004** | **For §7702**, “net surrender value” takes surrender charges into account but disregards policy loans. It is therefore distinct from both C003’s measure and net cash actually paid. | **S003, §7702(f)(2)(B)**. |\n| **R036-P1-C005** | **For §72(e)**, investment in the contract on a date is aggregate premiums or other consideration paid before that date, reduced by prior amounts received to the extent excludable under the subtitle or prior income-tax laws. The specific adjustments in C058, C068, and C072 must also be considered. “Basis” is not assumed to equal premiums, account value, or loan balance. | **S001, §72(e)(6), (e)(4)(A), (e)(11), (g)**. [uscode.house.gov](https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com) |\n| **R036-P1-C006** | The cash-value-accumulation test requires contract terms preventing cash surrender value at any time from exceeding the net single premium needed then to fund future benefits. Computation uses the greater of the applicable accumulation-test minimum rate or guaranteed issue rates, the specified mortality/additional-benefit charge rules, and the specified current/future-benefit assumptions. | **S003, §7702(b)(1)–(2)**, incorporating **(c)(3)(B)(i)–(ii), (e)(1)(A), (D)**. |\n| **R036-P1-C007** | For contracts issued **after December 31, 2020**, the accumulation-test minimum is the lesser of **4%** and the statutory insurance interest rate at issue; the guideline-premium minimum is that accumulation minimum **plus two percentage points**. The insurance interest rate is the lesser of the specified valuation and federal-rate measures for the adjustment year, or latest adjustment year. The federal-rate measure averages the prescribed **60 monthly mid-term rates**, annually compounded, and rounds to the nearest whole percentage point. The statutory **2% transition** begins January 1, 2021 and ends before the first adjustment year after 2021; it is not proof of a universal 2026 rate. | **S003, §7702(b)(3), (c)(3)(E), (f)(11)(A)–(E); P.L. 116-260 div. EE §205(e)**. No rate series or actuarial calculation performed. |\n| **R036-P1-C008** | Under the guideline-premium route, cumulative premiums paid cannot exceed the guideline-premium limitation at any time. That limitation is the greater of the guideline single premium or the sum of guideline level premiums to that date. | **S003, §7702(c)(1)–(2)**. |\n| **R036-P1-C009** | The guideline single premium is determined at issue, except for required adjustments, using the statutory mortality, reasonably expected charge, and interest assumptions. An unspecified charge is zero for this computation; industry experience substitutes for insufficient company experience only to the extent provided by regulations. Guideline level premiums run over a period not ending before insured age **95**, using the accumulation minimum instead of the higher guideline minimum. Prevailing tables and the statutory **three-year table-transition option** are separately relevant. | **S003, §7702(c)(3)–(4), (f)(10)**. Current mortality clause uses the statutory alternatives in **(c)(3)(B)(i)**; no actual table or charge assumption established. |\n| **R036-P1-C010** | Under the corridor route, the death benefit must at all times be at least the applicable percentage of cash surrender value. The percentage uses attained age at the beginning of the contract year and decreases ratably for each full year within the statutory bands reproduced immediately below. | **S003, §7702(d)(1)–(2)**; age rules in **S014**. These are qualification ratios, not income-tax rates or borrowing limits. |\n| **R036-P1-C011** | Except for the corridor calculation, §7702’s general assumptions deem death and qualified additional benefits nonincreasing, maturity between insured ages **95 and 100**, death benefits continuing to that deemed maturity, and endowment benefits—including maturity cash surrender value—not exceeding the least death benefit. Specified death-benefit increases may be recognized to preserve the excess over cash surrender value; the cash-value-accumulation alternative requires the stated net-level-reserve test and premium period not ending before age 95. | **S003, §7702(e)(1), (e)(2)(A)–(B)**. |\n| **R036-P1-C012** | A separate burial/funeral qualification rule permits specified increases for cash-value-accumulation testing only if initial death benefit is at most **$5,000**, maximum death benefit at most **$25,000**, annual fixed predetermined increase is at most **10% of initial benefit or 8% of preceding-year benefit**, and the purchase is for the specified burial/prearranged-funeral expenses. Initial death benefit aggregates **all contracts issued to the same owner**. This rule is excluded from the MEC seven-pay computational cross-reference. | **S003, §7702(e)(2)(C)**; **S002, §7702A(c)(1)(B)**. The burial-increase amendment applies to contracts entered into after **October 22, 1986**, per S003’s note. |\n| **R036-P1-C013** | §7702 “premiums paid” is its own measure: premiums less specified nontaxable §72(e) amounts, specified excess-premium distributions, and other amounts prescribed by regulations. A premium portion returned with interest to comply with the guideline requirement within **60 days after the contract year** reduces premiums for that year, excluding the interest; the returned interest is income. | **S003, §7702(f)(1)(A)–(C)**. This is not automatically the same measure as §72 investment or §7702A “amount paid.” |\n| **R036-P1-C014** | A premium otherwise exceeding the guideline limit is disregarded for that limit only to the extent necessary to prevent termination through the end of the contract year, and only if the contract has **no cash surrender value at the end of the extension period**. | **S003, §7702(f)(6)**. This is not a general excess-premium permission or loan exclusion. |\n| **R036-P1-C015** | An unreflected change in benefits or other terms requires proper adjustments in future §7702 determinations. A §7702 adjustment and a §7702A material change are related inquiries governed by different text. | **S003, §7702(f)(7)(A)**; compare **S002, §7702A(c)(3)**. |\n| **R036-P1-C016** | If an unreflected change reduces benefits during the **15-year period beginning on issue**, and a cash distribution results, §72 applies **without §72(e)(5)** up to the applicable recapture ceiling. Thus a qualifying contract outside the MEC rules can have a distribution for which the ordinary §72(e)(5) treatment is displaced. | **S003, §7702(f)(7)(B)**. The ceiling is not itself a declaration that its entire amount is taxable. [uscode.house.gov](https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com) |\n| **R036-P1-C017** | For a cash-value-accumulation contract and a reduction within the first **five years**, the recapture ceiling is the excess of cash surrender value immediately before reduction over the net single premium immediately afterward. | **S003, §7702(f)(7)(C)(i)**. |\n| **R036-P1-C018** | For a guideline-premium contract and a reduction within the first **five years**, the ceiling is the greater of: premiums before reduction exceeding the adjusted guideline limit; or cash surrender value before reduction exceeding the post-reduction cash-value corridor. | **S003, §7702(f)(7)(C)(ii)(I)–(II)**. |\n| **R036-P1-C019** | For a reduction after the first five years but within the first fifteen, the ceiling is the excess of pre-reduction cash surrender value over the post-reduction corridor, **whether or not the contract otherwise uses that corridor test**. | **S003, §7702(f)(7)(D)**. |\n| **R036-P1-C020** | The benefit-reduction rule also addresses anticipatory distributions. A distribution reducing cash surrender value and made within **two years before a benefit reduction** is statutorily treated as anticipatory; the ceiling provisions require appropriate adjustments. | **S003, §7702(f)(7)(E)**, including its regulatory direction. |\n| **R036-P1-C021** | Qualification failure is not automatically cured. The Secretary may waive failure only if the taxpayer establishes reasonable error and reasonable remedial steps to the Secretary’s satisfaction. | **S003, §7702(f)(8)**. No waiver, closing agreement, or request is assumed or pursued. |\n| **R036-P1-C022** | Variable contracts require additional classification checks. §7702 testing occurs whenever death benefits change and at least once each **12-month period**. §817 defines variable contracts and imposes a diversification condition, subject to its exceptions and regulatory rules. A “variable life” label alone does not establish qualification. | **S003, §7702(f)(9); S010, §817(d), (h)**. Detailed diversification application remains partial because §1.817-5 and actual investments are outside this completed reading. |\n| **R036-P1-C023** | A contract that is life insurance under applicable law but fails §7702(a) can produce annual ordinary income under §7702(g). The statutory annual measure is the excess of the increase in net surrender value plus the cost of protection over premiums paid. Protection cost is the lesser of the specified regulatory uniform-premium measure, using **five-year age brackets**, or stated mortality charge. | **S003, §7702(g)(1)(A), (B), (D)**. No annual amount established. |\n| **R036-P1-C024** | If such a contract ceases to qualify during a year, income on the contract for **all prior taxable years** is treated as received or accrued in the cessation year under the statutory catch-up rule. | **S003, §7702(g)(1)(C)**. This is a qualification-failure rule, not a universal lapse or loan-balance rule. |\n| **R036-P1-C025** | For a state-law life contract failing §7702(a), only death proceeds exceeding net surrender value receive the specified deemed-life-insurance treatment under §7702(g)(2). The contract nevertheless remains an insurance contract for the Code under (g)(3). Failure does **not** automatically make it a MEC or an ordinary annuity. | **S003, §7702(g)(2)–(3)**. Full beneficiary treatment remains unestablished. |\n| **R036-P1-C026** | Section 7702 extends its qualification/failure rules to applicable-law endowment contracts and separately defines qualifying endowment contracts for the Code. Section 72 also includes certain face-amount certificates issued after **December 31, 1954** within its endowment-contract terminology. These provisions prevent classification solely from a product title. | **S003, §7702(h); S001, §72(l)**. The incorporated securities-law certificate definition was not needed to classify an actual instrument and was not independently developed. |\n| **R036-P1-C027** | The applicable-law limb of §7702(a) is waived for the specified church-provided death-benefit arrangements for employees and beneficiaries, directly or through the specified organizations. The other federal qualification requirements are not thereby universally waived. | **S003, §7702(j)(1)–(3)**. No employment, church, or organizational facts supplied; application excluded. |\n| **R036-P1-C028** | The printed §7702(i) qualified-20-pay rule requires at least **20 nondecreasing annual premiums** and an existing plan filed before **September 28, 1983**, on file in the appropriate state. Its text substitutes 3% for 4% in §7702(b)(2). Because the 2020 amendment changed that subsection’s rate wording, a modern application of this legacy cross-reference is **not resolved here**. | **S003, §7702(i); P.L. 98-369 §221(d)(3); 2020 amendment notes**. Annual rather than monthly excess-interest crediting does not itself defeat the specified pre-1983-plan predicate. |\n| **R036-P1-C029** | Final §1.7702-2 governs attained age for specified §7702 tests: actual birthday age or a consistently used contract age within **12 months** of actual age, changing annually. First-to-die contracts use the oldest insured; last-to-die contracts generally use the youngest, with the prescribed youngest-surviving rule when both cash-value and future-mortality terms change at death. It applies to contracts issued after **December 31, 2008**, or on/after **October 1, 2007** using the specified 2001 tables; earlier use is permitted only under its consistency condition. | **S014, §1.7702-2(a)–(f)**. This actuarial insured-age rule does not establish the taxpayer-age exception under §72(v). |\n| **R036-P1-C030** | Section 7702 generally applies to contracts issued after **December 31, 1984**, in taxable years ending afterward. It also reaches specified increasing-death-benefit contracts issued after **June 30, 1984** with funding faster than ten-year level premiums, subject to C031–C032. For a master contract, the relevant issue date for an insured is first coverage. | **S003, P.L. 98-369 §221(d)(1), (2)(A), (5)**. |\n| **R036-P1-C031** | The early-1984 application has three alternative exceptions: a contract meeting the specified §101(f) test; a nonflexible-premium contract meeting the modified §7702 test using **3%** and the specified latest-maturity/20-year/age-95 assumption; or the specified periodically adjusted level-premium arrangement using at least **3%**, with a comparable death-benefit adjustment allowed at the insured’s option. | **S003, P.L. 98-369 §221(d)(2)(B)(i)–(iii)**. These are historical predicates, not a blanket pre-1985 exemption. |\n| **R036-P1-C032** | A further 1984 transition substitutes **September 30, 1984** for June 30 when the contract meets the specified modified §7702 test, disregards the specified mortality charges and initial excess-interest guarantees in determining guaranteed rates, and never exceeds the prescribed net-single-premium value. That value uses **3%**, the specified **1958** tables, and a level death benefit. A flexible-premium contract issued during 1984 that meets §7702 is treated as meeting §101(f). | **S003, P.L. 98-369 §221(d)(2)(C); §221(b)(3), as added in 1986**. |\n| **R036-P1-C033** | Section 101(f)’s pre-1985 flexible-premium category has its own predicates. It concerns premiums not fixed as to both timing and amount, excluding a state-law annuity portion other than a settlement option. Its death-payment condition requires either the guideline-limit/corridor route or the cash-value/net-single-premium route. Its corridor begins at **140%** through age 40, decreases one percentage point per later year, and bottoms at **105%**. Its guideline assumptions use guaranteed charges and the greater of **6%** or guaranteed rates, with **4%** for level premiums; its net-single-premium interest floor is **4%, or 3% for issuance before July 1, 1983**. It has distinct maturity, benefit-change, qualified-additional-benefit, premium-refund-within-60-days, necessary-premium, and reasonable-error provisions. These historical tests cannot be replaced by a current product label. | **S006, §101(f)(1)–(3)**, read completely. Cash value disregards surrender charges and policy loans; net-single-premium mortality uses the specified guaranteed/all-state-table predicate; maturity and endowment assumptions are those in **(2)(D), (3)(G)**. No actual death exclusion or actuarial determination made. |\n| **R036-P1-C034** | The 2017 mortality/table amendments have an effective-date rule for taxable years beginning after **December 31, 2017**. The accompanying reserve transition and eight-year reserve adjustment concern the specified reserve provisions; they are not a policyholder loan-income spreading rule. | **S003, amendment/effectiveness notes; S024, P.L. 115-97 §13517(c)(1)–(3)**. |\n\n**C010 — statutory corridor schedule**\n\n| Insured attained-age band, beginning of contract year | Applicable percentage, from → to |\n| --- | --- |\n| More than 0, not more than 40 | 250% → 250% |\n| More than 40, not more than 45 | 250% → 215% |\n| More than 45, not more than 50 | 215% → 185% |\n| More than 50, not more than 55 | 185% → 150% |\n| More than 55, not more than 60 | 150% → 130% |\n| More than 60, not more than 65 | 130% → 120% |\n| More than 65, not more than 70 | 120% → 115% |\n| More than 70, not more than 75 | 115% → 105% |\n| More than 75, not more than 90 | 105% → 105% |\n| More than 90, not more than 95 | 105% → 100% |\n\nThese are the statutory endpoints, with the ratable-full-year instruction in §7702(d)(2). No extension beyond the displayed bands or actual qualification calculation is inferred. [uscode.house.gov](https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com)\n\n### B. Modified endowment contract: definition, testing, changes, aggregation, and transitions\n\n| Claim ID | Supported proposition and consequential conditions | Exact authority and scope |\n| --- | --- | --- |\n| **R036-P1-C035** | A **modified endowment contract—MEC—must first meet §7702**. It is a contract entered into on or after **June 21, 1988** that fails the seven-pay test, or a qualifying contract received in exchange for such a MEC or a successor exchange contract. Failure of §7702 is not the MEC definition. | **S002, §7702A(a)(1)–(2)**. [uscode.house.gov](https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com) |\n| **R036-P1-C036** | The seven-pay test fails if, at any time during the first **seven contract years**, accumulated amount paid exceeds the cumulative net level premiums that would have been paid by then for paid-up future benefits after seven level annual premiums. It is not a comparison only at year-end or only against actual premiums scheduled by the contract. | **S002, §7702A(b)**. |\n| **R036-P1-C037** | Seven-pay premiums are determined at issue using §7702(b)(2) and (e), **excluding the burial-increase rule in §7702(e)(2)(C)**. The first-contract-year death benefit is deemed to continue through maturity, disregarding scheduled reductions after the first seven years. | **S002, §7702A(c)(1)**. Applicable historical interest assumptions still require the issue-date analysis. |\n| **R036-P1-C038** | A benefit reduction within the first seven contract years requires testing as though originally issued at the reduced level. A reduction attributable to nonpayment of premiums is disregarded for this rule if benefits are reinstated within **90 days after reduction**. | **S002, §7702A(c)(2)(A)–(B)**. No reinstatement or deadline is established for an actual contract. |\n| **R036-P1-C039** | An unreflected material change in benefits or other terms makes the contract a new contract, for §7702A, on the day the change takes effect. Seven-pay testing must make appropriate adjustments for cash surrender value under the contract. | **S002, §7702A(c)(3)(A)(i)–(ii)**. |\n| **R036-P1-C040** | Material changes include death-benefit increases and increases/additions of qualified additional benefits. The definition excludes increases attributable to premiums necessary to fund the lowest death-benefit/additional-benefit level payable in the first seven years, after the specified §7702(e)(2)(A)–(B) increases, and interest, earnings, or policyholder dividends on those necessary premiums. | **S002, §7702A(c)(3)(B)(i)**. |\n| **R036-P1-C041** | A cost-of-living increase is excluded from material-change treatment **only to the extent provided in regulations**, using an established broad-based index and ratable funding over the remaining required-premium period. The statutory regulatory authorization alone does not establish a particular increase qualifies. | **S002, §7702A(c)(3)(B)(ii)**. No applicable regulatory allowance was assumed. |\n| **R036-P1-C042** | If initial death benefit is at most **$10,000** and at least **seven nondecreasing annual premium payments** are required, each statutory seven-pay level premium is increased by **$75**. For this test, the contract and **all contracts previously issued by the same company to the same policyholder** are one contract. | **S002, §7702A(c)(4)**. This aggregation is not limited to one calendar year. |\n| **R036-P1-C043** | Expenses attributable solely to collection of premiums more frequently than annually can enter seven-pay computation only under rules prescribed by regulation. The statute does not itself provide an unrestricted expense adjustment. | **S002, §7702A(c)(5)**. |\n| **R036-P1-C044** | For the specified second-death or simultaneous-death contract, reduction below the lowest death benefit provided during the first seven contract years requires testing as originally issued at the reduced benefit. The reduction clause itself is **not limited to reductions occurring during those seven years**. This amendment applies to contracts entered into on or after **September 14, 1989**. | **S002, §7702A(c)(6); P.L. 101-239 §7647(b)**. |\n| **R036-P1-C045** | Failure affects distributions in the contract year of failure and later contract years, plus anticipatory distributions under the statutory/regulatory rule. A distribution within **two years before failure** is deemed anticipatory. Consequently a later failure can affect an earlier distribution; the text does not simply tax every outstanding balance upon reclassification. | **S002, §7702A(d)(1)–(2), concluding sentence**. |\n| **R036-P1-C046** | For seven-pay testing, “amount paid” means premiums less §72(e) amounts that are not included in gross income, **determined without the loan/pledge deeming rule in §72(e)(4)(A)**. This differs from both §72 investment and §7702 premiums paid. | **S002, §7702A(e)(1)(A)**. |\n| **R036-P1-C047** | A premium portion returned with interest to comply with the seven-pay test within **60 days after the end of the contract year** reduces that year’s premiums, excluding the interest. The returned interest is included in the recipient’s gross income notwithstanding §72(e). | **S002, §7702A(e)(1)(B)–(C)**. No actual correction or timely refund established. |\n| **R036-P1-C048** | A contract year is the **12-month period beginning with the first month for which the contract is in effect**, and corresponding successive periods. It is not necessarily a calendar year. Other §7702A terms generally take their §7702 meanings. | **S002, §7702A(e)(2)–(3)**. |\n| **R036-P1-C049** | The 1988 MEC amendments generally apply to contracts entered into on or after **June 21, 1988**. The successive-exchange clarification was made effective as part of the 1988 amendments. The 2002 enactment repealed the intervening “old contract” wording in the cash-value adjustment clause as though that amendment had not occurred. | **S002, P.L. 100-647 §5012(e)(1); P.L. 106-554 §318(a)(3); P.L. 107-147 §416(f)**. |\n| **R036-P1-C050** | For the historical issue-date transition, a death-benefit increase of **more than $150,000** over the benefit in effect on **October 20, 1988** invokes the material-change rules in determining post-June 20, 1988 status. This particular trigger does not apply if, as of June 21, 1988, at least seven level annual premiums were required and at least seven are actually made. | **S002, P.L. 100-647 §5012(e)(2)**. The exception is not automatically an exception to every other material-change rule. |\n| **R036-P1-C051** | A pre-June 21, 1988 contract is treated as later-entered if a death benefit or qualified additional benefit is increased/added on or after that date without a preexisting unilateral right to obtain it without additional insurability evidence; or if it is converted after June 20, 1988 from term to nonterm coverage, regardless of a prior conversion right. | **S002, P.L. 100-647 §5012(e)(3)(A)–(B)**. |\n| **R036-P1-C052** | A narrow historical exchange exception concerned MECs entered into after June 20 and before **November 10, 1988**, requiring at least seven level annual premiums, exchanged within **three months after enactment** for seven-pay-compliant life insurance, with an election to recognize gain notwithstanding §1035. It does not establish a presently available general MEC “reset.” | **S002, P.L. 100-647 §5012(e)(4)**. No calendar deadline calculated. |\n\n### C. Receipt, borrowing, distributions, investment recovery, and later events\n\n| Claim ID | Supported proposition and consequential conditions | Exact authority and scope |\n| --- | --- | --- |\n| **R036-P1-C053** | Section 72(e) addresses an amount received under an annuity, endowment, or life-insurance contract that is **not received as an annuity**, and only when another provision of the subtitle does not apply to that amount. A dividend or similar distribution is treated as nonannuity receipt. | **S001, §72(e)(1)(A)–(B)**. Classification comes before ordering. |\n| **R036-P1-C054** | For nonannuity life/endowment amounts within §72(e)(5)(C), absent its MEC/regulatory exceptions and other statutory overrides, §72(e)(2)(B)’s income-first allocation and §72(e)(4)(A)’s loan/pledge deeming do not apply. If the post-annuity-starting-date rule does not apply, inclusion is only to the extent the amount exceeds investment in the contract. Thus a genuine policy borrowing is not made a distribution **merely by the switched-off deeming rule**. | **S001, §72(e)(5)(A), (C)**; qualifications **C016–C020, C055, C068, C074**. This is not a finding that an actual advance is a genuine loan. [uscode.house.gov](https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com) |\n| **R036-P1-C055** | For a MEC, §72(e)(10) overrides the life/endowment exception, applies §72(e)(2)(B) and (4)(A), and substitutes **“any person”** for “an individual” in the deeming rule. Taxable income still depends on the applicable allocation and exceptions; MEC status does not make every dollar of every loan taxable. | **S001, §72(e)(10)(A)**; **S002, §7702A(d)**. |\n| **R036-P1-C056** | In the pre-annuity-starting-date income-first framework, the amount is allocated to income up to the excess, if any, of cash value **without surrender charge immediately before receipt** over investment then. The balance is allocated to investment. The statute’s own §72 measurement must be used; §7702’s separate definition is not silently substituted. | **S001, §72(e)(2)(B), (3)(A)–(B)**. Aggregation under C070 may change the relevant combined measurement. |\n| **R036-P1-C057** | Within that framework, direct or indirect receipt of an amount **as a loan under the contract**, or assignment, pledge, or agreement to assign/pledge a portion of contract value, causes that amount or portion to be treated as received as a nonannuity amount. The assigned/pledged portion is not automatically the face death benefit or the entire unassigned contract. | **S001, §72(e)(4)(A)(i)–(ii)**, with MEC substitution in **(e)(10)(A)(ii)**. A collateral event can matter without delivery of new cash by the insurer. |\n| **R036-P1-C058** | The loan/pledge deeming sentence does **not** itself apply in determining investment in the contract, except that investment increases by the amount actually included in gross income because of that deeming. Thus neither subtracting the entire deemed loan from investment nor adding the entire loan as a premium follows from this rule. | **S001, §72(e)(4)(A), final sentence**. Actual repayments and later applications of debt require separate characterization; no automatic repayment adjustment is invented. |\n| **R036-P1-C059** | A MEC assignment or pledge is excepted from §72(e)(4)(A) when it is **solely** to cover the burial/prearranged-funeral expenses referenced by §7702(e)(2)(C)(iii), and maximum death benefit is at most **$25,000**. The exception is for assignment/pledge; it is not an express exception for every loan. It does not import all the separate initial-benefit/increase limits of C012. | **S001, §72(e)(10)(B)**. |\n| **R036-P1-C060** | Section 72(e)(5) also protects the specified pre-**August 14, 1982** contract treatment, but investment allocable after **August 13, 1982** is treated as from a later contract. Accordingly an annuity comparison cannot simply assume that all old and new investment has identical income-first or loan-deeming treatment. | **S001, §72(e)(5)(B); P.L. 97-248 §265(c)**. No retirement-plan renewal transition is imported. |\n| **R036-P1-C061** | Section 72(e)(5)(E) separately covers amounts received on **complete surrender, redemption, or maturity**, and amounts received in full discharge of the contract obligation in the nature of a refund of consideration. It also switches off §72(e)(2)(A) for those amounts. Section 72(e)(10) overrides **(5)(C)**, not the separate full-surrender text in **(5)(E)**. | **S001, §72(e)(5)(A), (E), (10)(A); S013, §1.72-11(c)–(d)**. “Full discharge” here is not a blanket rule for cancellation of a borrower’s debt. |\n| **R036-P1-C062** | Rev. Rul. 2009-13 applies §72(e)(5) to a qualifying life contract’s surrender, treats the excess over investment as ordinary income, and does not reduce surrender investment by cost-of-insurance charges in its stated situation. Its surrender facts include no policy loans or prior distributions, so it does not establish a universal indebted-lapse calculation. | **S016**, Situation 1 analysis, printed **pp. 3–5 / PDF indexes 2–4**; holding 1, printed **p. 11 / index 10**. |\n| **R036-P1-C063** | Rev. Rul. 2009-13 must be read with Rev. Rul. 2020-05’s modifications concerning the later statutory adjusted-basis rule. Using the original ruling as wholly unchanged would misstate its status. The separate sale analyses are not a foundation for this component. | **S017**, printed **pp. 4–6 / indexes 3–5**, modifying S016; stated effective date transactions on/after August 26, 2009. |\n| **R036-P1-C064** | Publication 525’s cash-surrender explanation subtracts unrepaid loans not previously included in income in its simplified cost description. This supports the need to reconcile debt and cash in a surrender computation. It does **not** authorize simultaneously adding the same debt to gross proceeds and subtracting it again from statutory investment, or reducing §72(e)(6) investment every time a non-MEC loan originates. | **S018**, “Surrender of policy for cash,” read with **S001, §72(e)(4)(A), (5)(E), (6)**. The anti-double-counting conclusion is an analytical reconciliation, not an additional statutory formula. |\n| **R036-P1-C065** | The labels “lapse,” “termination,” “discharge,” and “write-off” do not by themselves identify a receipt or its measure. If an event constitutes a complete surrender or refund, C061 controls its ordering; if a MEC loan/pledge is deemed received, C055–C058 control. Whether a particular event applied value to debt, discharged a contractual obligation, or produced another legally relevant amount remains fact-dependent. | **S001, §72(e)(4), (5)(E), (6), (10); S018**. **Partial:** the selected noncase authorities do not establish one exhaustive treatment for every zero-cash lapse, interest capitalization, or debt discharge. |\n| **R036-P1-C066** | Cash originally advanced, an outstanding principal balance, accrued interest, newly capitalized interest, a new advance, repayment, and later contract settlement are distinct events or measurements. The read §72 provisions do not justify treating every unchanged balance as a new annual receipt or importing §72(p)’s plan-loan rules for interest, renewal, cure, or repayment. | **S001, §72(e)(4)(A), (6), (10); boundary (p)(1), (5)**. Treatment of a particular capitalization or refinancing remains unresolved without its legal character and pertinent published authority. |\n| **R036-P1-C067** | A dividend retained by the insurer as a premium or other consideration is not included under §72(e)(2)(B)(i) to that extent. A cash dividend and a retained-premium dividend therefore require different facts and cannot automatically be treated as either a loan or newly paid outside cash. | **S001, §72(e)(1)(B), (4)(B), (6)**. |\n| **R036-P1-C068** | A charge against annuity cash value or life-insurance cash surrender value for coverage under a **qualified long-term-care contract that is part of or a rider on the contract** is not included in income under §72(e)(11), notwithstanding the specified ordinary/MEC rules. It reduces investment, but not below zero. The 2006 provision generally applies to contracts issued after **December 31, 1996**, for taxable years beginning after **December 31, 2009**. | **S001, §72(e)(11); P.L. 109-280 §844(g)(1)**. No rider qualification assumed. |\n| **R036-P1-C069** | Qualified long-term-care status requires the separate §7702B predicates, including qualified services, the specified Medicare coordination, guaranteed renewability, restrictions on cash/borrowing/assignment values, premium-refund treatment, and consumer-protection requirements. Section 7702B(e) separates the rider portion and denies a §213 deduction for the specified value-funded charge. Issuance of a qualified rider, or adding provisions needed to conform another long-term-care rider, is **not a modification/material change for §§101(f), 7702, or 7702A** under the enactment note. | **S011, §7702B(b), (c), (e), (g); P.L. 104-191 §321(f)(4)**. Incorporated qualification standards and actual eligibility remain unestablished. |\n| **R036-P1-C070** | For §72(e) inclusion, all MECs issued by the **same company to the same policyholder during a calendar year** are one MEC; annuities have a corresponding aggregation rule. The rule excludes §72(e)(5)(D) contracts. Additional anti-abuse rules require regulations; “all related contracts everywhere” is not the text. For annuities, the 1988 subsection-(d) amendments apply to contracts entered into **after October 21, 1988**. | **S001, §72(e)(12)(A)–(B); S002, P.L. 100-647 §5012(e)(5)**; 1989 calendar-year amendment note. |\n| **R036-P1-C071** | An individual’s transfer of an **annuity** without full and adequate consideration has a separate deemed-receipt rule for cash surrender value exceeding investment, with the §1041(a) exception and a transferee investment increase for the amount included. This is not automatically the rule for a collateral assignment of a life contract. | **S001, §72(e)(4)(C)(i)–(iii)**. Full gift/divorce analysis excluded. |\n| **R036-P1-C072** | For a transfer for value whose transferee basis is not determined by reference to the transferor’s basis, §72(g) uses actual consideration plus subsequent transferee premiums/consideration, specified transferee prior receipts, and the transferee’s annuity starting date. “Transferee” includes its beneficiary or estate. A pledge alone does not establish all these transfer-for-value predicates. | **S001, §72(g)(1)–(3), concluding sentence**. |\n| **R036-P1-C073** | Amounts actually received **as an annuity** are governed by §72(a)–(c), including the investment/expected-return framework and annuity-starting-date definition, rather than automatically by nonannuity withdrawal ordering. Qualifying partial annuitization for **ten years or more or one or more lives** creates a separate portion, pro rata investment allocation, and separate starting date; the 2010 amendment applies to taxable years beginning after **December 31, 2010**. | **S001, §72(a)–(c), P.L. 111-240 §2113(b); S012, §1.72-2(b)**. Historical annuity-starting-date rules and actuarial tables are not calculated or certified here. |\n| **R036-P1-C074** | A nonannuity amount received **on or after the annuity starting date** is generally included under §72(e)(2)(A), subject to the applicable statutory exceptions, including the full-refund/surrender rule in C061. The pre-start loan/ordering analysis cannot simply be copied to every post-start event. | **S001, §72(e)(2)(A), (5)(A), (5)(E)**. |\n| **R036-P1-C075** | If a contract provides a full-discharge lump sum with an annuity option, the option is exercised within **60 days after the lump sum first becomes payable**, and some or all would otherwise be included under §72(e)(1), §72(h) prevents inclusion merely when that lump sum first becomes payable. | **S001, §72(h)(1)–(3)**. No exercise or deadline determined. |\n| **R036-P1-C076** | Interest payments on an amount held under an agreement to pay interest are income notwithstanding other §72 provisions. That recipient interest is distinct from interest charged on a policy borrowing. | **S001, §72(j)**. |\n| **R036-P1-C077** | Qualified-plan/IRA contracts have expressly separate §72(e)(5)(D)/(8) treatment. Section 72(p)(5) treats a loan, assignment, or pledge of a contract purchased under a qualified employer plan as a plan loan. These boundaries prevent importing the independent-policy analysis into a retirement arrangement or importing retirement-plan loan limits into this component. | **S001, §72(e)(5)(D), (8), (p)(1), (5)**. The separate retirement-plan-loan report was not used or regenerated. |\n\n### D. Additional tax and annuity boundaries\n\n| Claim ID | Supported proposition and consequential conditions | Exact authority and scope |\n| --- | --- | --- |\n| **R036-P1-C078** | If a taxpayer receives an amount under a MEC, §72(v)(1) increases tax for the receipt year by **10% of the portion included in gross income**, subject to its exceptions. The base is not automatically gross cash, original borrowing, death benefit, or outstanding principal. | **S001, §72(v)(1)**, read with **(e)(4)(A), (10)** for deemed receipts. [uscode.house.gov](https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com) |\n| **R036-P1-C079** | The age exception applies to a distribution made **on or after the date the taxpayer attains 59½**. The insured’s age, contract age, or another role’s age does not establish this predicate. | **S001, §72(v)(2)(A)**. |\n| **R036-P1-C080** | The disability exception requires the distribution to be attributable to the taxpayer’s becoming disabled within §72(m)(7): inability to engage in any substantial gainful activity because of a medically determinable physical or mental impairment expected to result in death or to be long-continued and indefinite, with proof in the form and manner required by the Secretary. | **S001, §72(v)(2)(B), (m)(7)**. No disability or medical fact inferred. |\n| **R036-P1-C081** | The periodic-payment exception requires a distribution to be part of substantially equal periodic payments, **at least annually**, for the taxpayer’s life/life expectancy or the joint lives/joint life expectancies of the taxpayer and beneficiary. A single withdrawal, a repayment schedule, or the insurer’s installment label does not establish this exception. | **S001, §72(v)(2)(C)**. No payment method, life-expectancy calculation, or modification conclusion supplied. |\n| **R036-P1-C082** | The retrieved §72(v)(2) contains the three exceptions in C079–C081. It does not contain §72(q)’s separate death, immediate-annuity, pre-1982-investment, or other listed exceptions. Nor does a reporting code establish a new statutory exception. This does not imply that a death payment is necessarily taxable; §101 must first be addressed. | **S001, §72(v)(2), compared with (q)(2); S006, §101(a)**. |\n| **R036-P1-C083** | For an **annuity**, §72(q) has its own 10%-of-includible-amount rule and exceptions: taxpayer age 59½; holder’s death or specified primary-annuitant death; disability; qualifying periodic payments; specified qualified arrangements; pre-August 14, 1982 investment; a qualifying funding asset; amounts governed by §72(t); an immediate annuity; and the specified employer-purchased contract following plan termination. These are annuity boundaries, not MEC exceptions. | **S001, §72(q)(1)–(2)(A)–(J), (s)(6)(B), (u)(4)**. An immediate annuity requires a single premium/consideration, starting within one year, and substantially equal payments at least annually. |\n| **R036-P1-C084** | Section 72(q)(3) expressly addresses subsequent modification of qualifying periodic payments, other than death/disability, before age 59½ or within the specified five-year period after payments begin, with recapture and deferral interest. Its §1035-exchange exception requires combined distributions to continue satisfying the periodic-payment requirement. The relevant exchange amendment applies to exchanges after **December 31, 2023**, with an express no-inference rule for earlier law. | **S001, §72(q)(3)(A)–(B); P.L. 117-328 div. T §323(e)**. This annuity recapture text is not automatically imported into §72(v). |\n| **R036-P1-C085** | An annuity held by a nonnatural person can fall under §72(u)’s current ordinary-income regime rather than ordinary annuity deferral, subject to the natural-person-agent rule and the express estate-at-death, qualified-arrangement, qualified-funding-asset, employer-termination-contract, and immediate-annuity exceptions. Its enactment applicability concerns contributions after **February 28, 1986**. | **S001, §72(u)(1)–(4); P.L. 99-514 §1135(b)**. No entity, ownership, or annual-income computation established. |\n| **R036-P1-C086** | **Unresolved authority issue:** the 2026 Form 1099-R code notes refer to modifying substantially equal periodic payments under §72(q), **(v)**, or (t) before five years, even after age 59½. The retrieved §72(v) has no express recapture paragraph corresponding to §72(q)(3). The instruction supports its stated reporting direction; it does not, by itself, establish the substantive §72(v) recapture base, interest, or legal authority. | **S019**, Table 1, code **1** and code **7** notes; **S001, §72(v), compared with (q)(3)**. No independent published authority resolving this issue was established in this investigation. [Internal Revenue Service+1](https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com) |\n\n### E. Interest and deduction limitations\n\n| Claim ID | Supported proposition and consequential conditions | Exact authority and scope |\n| --- | --- | --- |\n| **R036-P1-C087** | Section 264(a)(2) denies deductions for amounts paid/accrued on debt incurred or continued to purchase or carry a single-premium life, endowment, or annuity contract. For this purpose, substantially all premiums within **four years of purchase**, or a post-**March 1, 1954** deposit funding a substantial number of future premiums, can make a contract single-premium. The annuity application of (a)(2) is limited to contracts purchased after March 1, 1954. | **S004, §264(a)(2), concluding applicability sentence, (c)(1)–(2)**. [uscode.house.gov](https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com) |\n| **R036-P1-C088** | For contracts purchased after **August 6, 1963**, §264(a)(3) addresses purchase/carry debt under a plan contemplating systematic direct or indirect borrowing of cash-value increases, from the insurer **or otherwise**, excluding single-premium contracts already covered by (a)(2). | **S004, §264(a)(3), concluding applicability sentence**. |\n| **R036-P1-C089** | The four §264(d) exceptions apply **to (a)(3)**: no debt financing of any part of four annual premiums due during the specified seven-year period; otherwise-disallowed annual paid/accrued amounts no more than **$100**; debt arising from an unforeseen substantial income loss or financial-obligation increase; or trade/business debt. A substantial premium increase restarts that seven-year period when the first increased premium is paid. | **S004, §264(d)(1)–(4), concluding sentence**. These exceptions do not erase (a)(2), (a)(4), or §163. |\n| **R036-P1-C090** | Section 264(a)(4) separately denies interest deductions on indebtedness with respect to taxpayer-owned life policies covering any individual, or taxpayer-owned endowment/annuity contracts covering any individual, subject to subsection (e). Its purchase-date boundary is **after June 20, 1986**. It is not conditioned on MEC status. | **S004, §264(a)(4), concluding applicability sentence; P.L. 99-514 §1003(c)**. |\n| **R036-P1-C091** | The key-person exception removes the (a)(4) bar only to the extent aggregate relevant indebtedness for policies/contracts covering the key individual does not exceed **$50,000**. This is neither a tax-free loan allowance nor a contractual borrowing ceiling. Other deduction restrictions remain. | **S004, §264(e)(1)**. |\n| **R036-P1-C092** | A key person is an officer or **20-percent owner**, with the permitted number capped at the greater of five or the lesser of 5% of officers/employees and twenty. Corporate ownership uses direct stock or voting ownership; other entities use capital/profits interests. Controlled-group aggregation applies to the stated ownership test and $50,000 limit, with allocation as prescribed. | **S004, §264(e)(3)–(5)**. Incorporated §§52 and 414 business-group application remains outside the completed component. |\n| **R036-P1-C093** | The key-person/pre-1986 deduction allowance is further capped for months beginning after **December 31, 1995** by the monthly corporate-bond benchmark specified in §264(e)(2). For contracts purchased on/before June 20, 1986, fixed-rate contracts use the purchase-month benchmark; variable-rate contracts use the third month before the applicable period. That period is normally successive twelve-month periods, with the statutory shorter-period election, historical 90-day election requirement, and consent-to-revoke condition. | **S004, §264(e)(2)(A)–(B)**. No benchmark lookup, historical election, interest rate, or deduction amount established. |\n| **R036-P1-C094** | Section 264(f) has a separate proportional interest-disallowance regime based on average **unborrowed policy cash values** for specified post-June 8, 1997 contracts relative to the stated asset denominator. Its unborrowed-value measure generally subtracts loans from cash surrender value determined without surrender charges, with an alternative valuation rule if that does not reasonably approximate actual value. | **S004, §264(f)(1)–(3), (7)**. This is a third distinct value measure; no averaging convention or business deduction is computed. |\n| **R036-P1-C095** | Section 264(f)’s exceptions and coordination matter: specified single-insured business contracts, the owner-and-spouse allowance, §72(u) annuities, qualifying separate master-contract coverage, natural-person ownership, and insurance-company exclusions. The natural-person exception has a business-beneficiary override, with sole-proprietorship/employee-business exclusions and a benefit cap. Partnerships/S corporations are tested at entity level; controlled-group aggregation and coordination with §§264(a), 265, and 263A apply. | **S004, §264(f)(4)–(8)**, read completely. Full incorporated business-tax analysis remains excluded. |\n| **R036-P1-C096** | Premium deduction and interest deduction are separate questions. Section 264(a)(1) denies premiums where the taxpayer is directly or indirectly a beneficiary, subject to the specified annuity exceptions in (b). A premium’s inclusion in §72 investment does not itself create a deduction. | **S004, §264(a)(1), (b); S001, §72(e)(6)**. |\n| **R036-P1-C097** | The 1996 amendments generally apply to interest paid/accrued after **October 13, 1995**, with a historical transition ending before January 1, 1999 for specified earlier debt. The 1997 amendments generally apply to contracts issued after **June 8, 1997**, in taxable years ending afterward; material death-benefit increases or other material changes can make a contract new for that transition, and added lives under a master contract have the stated separate treatment. | **S004**, P.L. 104-191 §501(c); **S006**, P.L. 105-34 §1084(d). Historical transition qualification requires the original debt dates, specified interest cap, aggregation, insured-count limit, and annual percentages; none is applied to current interest. |\n| **R036-P1-C098** | The historical four-year income-spreading provision concerns otherwise-taxable amounts under specified §264(a)(4) contracts on complete surrender/redemption/maturity, or a qualifying full-discharge refund, during **1996, 1997, or 1998**. It is not a general current surrender or lapse spreading rule. The associated historical premium-test provision also has its own express lapse predicate and former-subsection references. | **S004**, P.L. 104-191 §501(d)(1)–(2), as amended. No present relief inferred from the note’s continued display. |\n| **R036-P1-C099** | Even if a §264 bar does not apply, §163 remains a separate gate. Section 163(a)’s general interest rule is limited by §163(h)’s prohibition of personal-interest deductions for noncorporate taxpayers and applicable exceptions. An exception to a disallowance is not affirmative proof of deductibility. | **S005, §163(a), (h)(1)–(2); S004**. Full deduction tracing and all §163 exceptions remain held. |\n| **R036-P1-C100** | These tax provisions establish inclusion, exclusion, and deduction conditions. They do not supply a contractual right to borrow, an insurer’s repayment terms, protection against lapse, or a suitability recommendation. A deduction limitation is not a prohibition on borrowing. | Scope of **S001, S003–S005**; contractual/insurance-law analysis expressly excluded by the parent holds. |\n\n### F. Exchanges and death-benefit boundaries\n\n| Claim ID | Supported proposition and consequential conditions | Exact authority and scope |\n| --- | --- | --- |\n| **R036-P1-C101** | Section 1035 permits specified exchanges: life to life/endowment/annuity/qualified long-term-care; endowment to qualifying endowment with payments beginning no later, annuity, or qualified long-term-care; annuity to annuity or qualified long-term-care; qualified long-term-care to qualified long-term-care. It does not list annuity-to-life as a permitted direction. Section-specific definitions and the foreign-person limitation remain relevant. | **S007, §1035(a)–(c)**. No replacement transaction recommended or assumed. |\n| **R036-P1-C102** | The read final regulation requires the same insured for insurance exchanges and the same obligee or obligees for annuity exchanges. An ownership/insured change is not automatically a qualifying exchange merely because another contract is acquired. | **S015, §1.1035-1**; current statutory categories in **S007** control later additions. Original regulatory issuance-date gap remains recorded. |\n| **R036-P1-C103** | Money, other property, and liability assumption can prevent complete nonrecognition. Through §1035(d), §1031(b)–(d) supplies gain-recognition, no-loss, basis, and liability-as-money rules. The incorporated §357(d) definition treats recourse and nonrecourse liabilities differently and requires the specified agreement, expected-payment, collateral, and allocation facts. | **S007, §1035(d); S008, §1031(b)–(d); S009, §357(d)(1)–(3)**. No automatic conclusion that every loan balance is taxable “boot.” |\n| **R036-P1-C104** | A qualifying §1035 exchange generally carries the prescribed adjusted investment/basis framework rather than resetting everything to a new cash premium. Separately, §7702A(a)(2) preserves MEC classification through successive exchanges. Income nonrecognition and MEC status are different questions. | **S007, §1035(d); S008, §1031(d); S002, §7702A(a)(2)**. |\n| **R036-P1-C105** | Section 101’s death-payment exclusion is subject to its own exceptions and limits, including transfer-for-value/reportable-sale rules and separate interest treatment. A MEC still satisfies §7702 by definition, so MEC status alone does not establish the death benefit’s tax result. No beneficiary, death, ownership, transfer, or employer facts are supplied. | **S006, §101(a), (c), (d), (f); S002, §7702A(a); S003, §7702(g)(2)**. Full death-benefit, estate, gift, and employment analysis remains held. |\n\n### G. Reporting and withholding are separate from substantive liability\n\n| Claim ID | Supported proposition and consequential conditions | Exact authority and scope |\n| --- | --- | --- |\n| **R036-P1-C106** | Section 6047(d) authorizes/requires the specified issuer reporting for contracts from which designated distributions may be made, as prescribed. Its **$10 aggregate annual threshold** is a reporting provision, not an income exclusion. Section 6047(g) coordinates with information required under §6050Y. | **S021, §6047(d)(1)–(2), (g)**. Actual filer/event status and full reporting rules remain unestablished. |\n| **R036-P1-C107** | For §3405 withholding, “commercial annuity” expressly includes a life-insurance or endowment contract issued by a state-licensed insurance company. That withholding definition does not reclassify every life contract as an annuity for §72’s substantive treatment. Designated distributions, exclusions, payor responsibility, and the cash/property withholding limitation require their own predicates. | **S022, §3405(d), (e)(1), (6), (8)**. No withholding election, rate, or obligation determined. |\n| **R036-P1-C108** | Amounts withheld under chapter 24 are credited under §31(a); withholding is not itself the final income-tax liability. | **S020, §31(a)(1)–(2)**. |\n| **R036-P1-C109** | The inspected **2026** instructions identify box **1** as gross distribution, **2a** as taxable amount, **2b** as relevant determination/distribution checkboxes, **4** as federal income tax withheld, **5** as the specified contributions/premiums recovered, and **7a** as distribution codes. The 2026 renumbering must not be silently replaced by an older box-number convention. | **S019**, “What’s New,” and instructions for those boxes. This describes instructions actually read, not a completed form. |\n| **R036-P1-C110** | The instructions direct reporting of matured/redeemed insurance and annuity payments, but state that a life-insurance surrender need not be reported on Form 1099-R when it is reasonable to believe none of the payment is includible. This conditional instruction does not establish that an actual surrender occurred or that any actual payer met the belief predicate. | **S019**, “Life insurance, annuity, and endowment contracts.” |\n| **R036-P1-C111** | A qualifying §1035 exchange can be reportable despite nonrecognition. The instructions separately address loan cancellation or other property and provide the stated within-company exception where the transaction is solely an exchange, no designated distribution occurs, and adequate basis records are maintained. | **S019**, “Section 1035 exchange.” This reporting exception is not the substantive qualification test. |\n| **R036-P1-C112** | In the inspected code table, **L** is for deemed distributions under **§72(p)**, not every policy loan. Code **6** addresses §1035 exchanges; code **7** includes the stated life/annuity/endowment and failed-§7702 reporting; **W** addresses qualifying §72(e)(11) long-term-care charges. A code does not prove qualification, income amount, or an additional-tax exception. | **S019**, Table 1, codes **6, 7, L, W**; see unresolved code-note issue **C086**. [Internal Revenue Service](https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com) |\n| **R036-P1-C113** | No actual information return, withholding entry, payer determination, or tax return has been supplied. Therefore this investigation establishes conditional reporting functions only; it does not establish an actual filing duty, taxable box amount, withholding liability, or final tax bill. | Application limits of **S019–S022**, and the user’s held facts. |\n\n## 3. Provision-specific comparison\n\n| Question | Qualifying life contract outside MEC treatment | MEC | Annuity or other separately governed contract | Unknown/nonqualifying contract |\n| --- | --- | --- | --- | --- |\n| **Classification prerequisite** | Applicable version of §7702 or historical framework must be satisfied; MEC status must separately be excluded. | Must meet §7702 and satisfy §7702A’s failure/exchange definition. | Contract and payment classification must be established; qualified arrangements and §72(u) are separate boundaries. | No favorable classification is presumed. A state-law life contract failing §7702 can trigger §7702(g). |\n| **Ordinary pre-start cash withdrawal** | §72(e)(5) generally recovers investment before inclusion, subject to benefit-reduction and other overrides. | §72(e)(2)(B)/(3) generally allocates income first. | Generally the pre-start income-first framework, but old-investment and qualified-arrangement exceptions matter. | No ordering rule selected until legal classification is established. |\n| **Loan under contract** | §72(e)(5)(C) generally turns off §72(e)(4)(A) deeming; actual loan character remains necessary. | Direct/indirect loan receipt is deemed nonannuity receipt, with income allocation and the specific investment increase. | §72(e)(4)(A) can apply to an individual within its framework; grandfathered investment and other exceptions matter. | No blanket borrowing exclusion or deemed-distribution rule established. |\n| **Assignment/pledge/agreement** | The same §72(e)(5)(C) switch-off generally applies; an outright transfer remains a different inquiry. | Assigned/pledged value can be deemed received; narrow burial/funeral exception may apply. | Loan/pledge deeming and the distinct annuity transfer-without-consideration rule must not be confused. | Actual legal character, amount, and applicable regime remain unknown. |\n| **Complete surrender/refund/maturity** | §72(e)(5)(E) governs qualifying complete events, with investment recovery. | The separate full-event rule must still be considered; MEC status alone does not erase (5)(E). | Same full-event provision can apply; regular annuity payments have a different recovery regime. | Event classification and any §7702(g) effects must first be resolved. |\n| **Lapse/termination with debt** | No universal result from the label; determine the legal receipt/settlement and reconcile debt, value, investment, and prior treatment. | Same event inquiry, plus prior deemed receipts, basis increases, aggregation, and MEC timing. | Applicable annuity/other regime and actual event required. | No amount, write-off, cancellation-income treatment, or absence of income inferred. |\n| **Additional tax** | §72(v) does not apply merely because it is life insurance. | §72(v): 10% of includible amount unless its own exception applies. | §72(q) is separate; qualified arrangements have separately held rules. | No additional-tax provision or exception selected from labels alone. |\n| **Interest deduction** | §§264 and 163 apply independently of favorable borrowing treatment. | Same separate deduction inquiry; MEC status is not the sole test. | Relevant §264/§163 provisions and contract-date boundaries remain separate. | No deduction inferred. |\n| **Reporting** | Reporting can depend on a later distribution even if an earlier genuine borrowing was not deemed received. | A deemed receipt can matter without equivalent cash delivery. | Tax-free exchanges and other events may still be reportable. | A form or code cannot cure missing substantive classification. |\n\n**Comparison claim links:** C002–C005, C023–C025, C035, C045, C053–C077, C078–C086, C087–C113. **Source links:** S001–S007, S013, S018–S022.\n\n## 4. Substantive qualitative branches\n\n“Answered” below concerns the stated public-law rule. **Every actual-contract application remains unresolved** because the relevant facts are held. “Partial” identifies an additional public-authority gap.\n\n| Branch | Supported conditional rule and exact claim/source links | Missing evidence, held rather than requested | Adverse inference to avoid | Next permissible public-law inquiry |\n| --- | --- | --- | --- | --- |\n| **B01 — Contract qualification unknown** | **Answered rule:** §7702 requires applicable-law status plus the selected federal test; failure can invoke §7702(g). **C002, C006–C025; S003 §§7702(a)–(g).** | Applicable qualification regime, selected test, compliance history, any failure or waiver. | Marketing category establishes federal life-insurance status; failure means MEC. | Read any further published Treasury qualification rule implicated by the identified legal category; no insurer or policy search. |\n| **B02 — Life contract versus annuity** | **Answered boundary:** §72 distinguishes the contract from whether a payment is received as an annuity; qualified arrangements and §72(u) are separate. **C053, C073–C077, C083–C085; S001, S012.** | Contract classification, payment character, ownership category, annuity starting status. | Every insurer-issued product, or every installment payment, gets life-policy loan treatment. | Examine the relevant portions of final §1.72 regulations and statutory category definitions only. |\n| **B03 — MEC status unknown** | **Answered rule:** §7702A requires §7702 qualification plus seven-pay failure or the exchange rule. **C035–C048; S002 §7702A(a)–(e).** | Seven-pay determination, amount-paid history, benefit history, prior exchange status. | All permanent policies are MECs, or an unexplained label proves non-MEC status. | Further published generic guidance on the particular seven-pay computational issue; no private ruling/request. |\n| **B04 — Issue/change/exchange date unknown** | **Answered transitions; partial legacy cross-reference:** issue, conversion, change, and exchange dates can select different statutory rules. **C007, C028–C034, C044, C049–C052; S002–S003, S006, S014, S024.** | Relevant legal dates and character of changes; historical unilateral rights. | A single original issue date preserves every grandfather rule indefinitely. | Read published guidance resolving the relevant transition, including the §7702(i) cross-reference if that category becomes relevant. |\n| **B05 — Investment unknown** | **Answered rule:** premiums/consideration less prior excluded amounts, with particular deemed-receipt and rider adjustments. **C005, C058, C068, C072; S001 §72(e)(4), (6), (11), (g).** | Premium/consideration history, prior recoveries, taxable deemed receipts, transfer and rider adjustments. | Cash value, death benefit, premium total, or debt balance automatically equals investment. | Published §72 guidance on the particular adjustment; keep investment and adjusted sale basis separate. |\n| **B06 — Loan versus distribution** | **Answered conditional rule:** actual loan character matters; the non-MEC switch-off and MEC switch-on differ. **C053–C058; S001 §72(e)(1)–(6), (10).** | Legal character of advance, direct/indirect receipt, pre/post-annuity-start status. | Any cash delivery is taxable income, or every item called a loan is excluded. | Published interpretation of the precise generic transaction category under §72(e). |\n| **B07 — Collateral assignment/pledge** | **Answered rule:** an agreement to assign/pledge a portion can trigger MEC deeming; narrow burial exception is separate. **C057, C059, C071–C072; S001 §72(e)(4), (10)(B), (g).** | Portion affected, collateral versus ownership transfer, agreement, purpose, maximum benefit. | No cash means no possible receipt; every assignment is a sale; entire face amount is deemed received. | Published final rules or interpretations distinguishing collateral assignment, outright transfer, and the statutory burial exception. |\n| **B08 — Outstanding debt and interest unknown** | **Partial:** distinguish principal, accrued/capitalized interest, new advances, repayment, and later application of value. **C058, C065–C066; S001, S018.** | Debt composition, prior taxation, capitalization mechanics, later settlement character. | All outstanding debt is newly taxable each year; retirement-plan accrued-interest instructions govern policy loans. | Search only published Treasury/IRS guidance on capitalization, repayment, and repeated deemed receipts under §72(e). |\n| **B09 — Surrender/lapse/termination unknown** | **Answered surrender rule; partial exhaustive lapse treatment:** complete events invoke §72(e)(5)(E); labels alone do not establish a receipt. **C061–C065; S001, S013, S016–S018.** | Actual event, proceeds/value application, surviving rights, discharged obligation, prior basis recovery. | Every lapse produces the same tax, or a lender necessarily writes off debt. | Published generic guidance specifically addressing the relevant noncash termination mechanism; no case-record inquiry. |\n| **B10 — Gross proceeds versus cash received** | **Answered distinction; partial event measure:** reconcile gross contract receipt, debt application, charges, withholding, and net cash without double counting. **C003–C005, C056, C064, C109; S001, S003, S018–S019.** | Gross settlement components and prior taxable/excluded amounts. | Zero cash proves zero income; debt is counted both in gross proceeds and again as a basis reduction. | Published guidance identifying the legally appropriate gross/net convention for the event. |\n| **B11 — Aggregation/related contracts unknown** | **Answered statutory rules:** calendar-year MEC/annuity grouping differs from all-prior-contract small-benefit grouping and same-owner burial grouping. **C012, C042, C070; S001–S003.** | Same-company, same-policyholder/owner, issue-calendar-year, prior-contract, and excluded-plan predicates. | Every related contract aggregates, or none does; “contract year” means calendar year. | Published anti-abuse regulations or interpretations for the precise aggregation provision. |\n| **B12 — Additional-tax exception unknown** | **Answered statutory exceptions; partial modification issue:** §72(v) taxes the includible portion, with taxpayer-age, disability, or qualifying periodic-payment exceptions. **C078–C086; S001, S019.** | Taxpayer-role facts, relevant age/event, qualifying payment series; all remain held. | Insured age suffices; hardship or annuity death exceptions automatically transfer to MECs. | Published authority resolving §72(v) periodic-payment methods/modification and the instruction’s five-year reference. |\n| **B13 — Interest deduction separate** | **Answered restrictions:** §§264/163 impose independent gates and narrow exceptions. **C087–C099; S004–S005, S006 note.** | Purchase/debt dates, purpose, ownership, business/key-person predicates, actual interest/elections. | Nontaxable loan proceeds imply deductible interest; a §264 exception proves a deduction. | Generic published guidance for the specifically implicated §264 or §163 limitation, within the parent’s deduction hold. |\n| **B14 — Reporting versus substantive tax** | **Answered distinction:** reporting fields and withholding classify information, not final liability; code L is §72(p). **C086, C106–C113; S019–S022.** | Actual reportable event, payer predicates, report/version, withholding facts. | A sample box, code, or withholding amount establishes tax or a filing duty. | Current public instructions and relevant final reporting regulations for the identified event; no filling or filing. |\n| **B15 — Death/beneficiary treatment not established** | **Answered boundary:** §101 is separate, with its own exceptions; MEC status alone does not determine a death benefit. **C025, C082, C105; S002–S003, S006.** | Death, beneficiary-role, transfer, ownership, and other §101 predicates. | “Death benefits are tax-free” supplies authority for lifetime borrowing. | Only the relevant published §101 provision if this boundary must later be developed; full death-benefit work stays held. |\n| **B16 — Tax rule versus insurance consequence** | **Answered scope distinction:** tax treatment supplies no borrowing right or coverage/suitability conclusion. **C100; S001, S003–S005.** | Contractual rights, interest terms, repayment, lapse/coverage effects, nonfederal law. | A favorable tax branch makes borrowing safe, available, or advisable. | No further inquiry in this pass; those subjects are expressly held. |\n| **B17 — Benefit reduction unknown** | **Answered rules:** first-seven-year MEC retesting and first-fifteen-year cash-distribution recapture are different; each has its own lookback/exceptions. **C015–C020, C038, C044–C045; S002–S003.** | Reduction type/date, distribution relationship, reinstatement, joint-life structure. | A non-MEC withdrawal is invariably investment-first; all reductions use one clock. | Published guidance on the identified reduction and the relevant statutory ceiling or retesting rule. |\n| **B18 — Exchange unknown** | **Answered statutory boundary; partial historic regulation metadata:** permitted direction, same-insured/obligee, boot/liability, basis, and MEC carryover are separate. **C101–C104; S002, S007–S009, S015.** | Exchange character, consideration, debt assumption, qualifying roles, prior status. | A replacement resets MEC status or every debt balance is taxable exchange consideration. | Published §1035 interpretation and original final-rule history pertinent to the precise generic exchange issue. |\n| **B19 — Long-term-care charge/rider unknown** | **Answered conditional rule:** qualifying value-funded charges have special exclusion/investment reduction; qualifying rider changes have a specific material-change exception. **C068–C069; S001, S011.** | Qualified rider status, charge character, relevant dates, incorporated qualification predicates. | Every rider charge is an ordinary withdrawal; every rider addition creates a new MEC test period. | Published §7702B/§72(e)(11) guidance and applicable incorporated standards, without medical or policy records. |\n| **B20 — Annuity starting date unknown** | **Answered boundary:** nonannuity receipts before and after that date, regular annuity payments, and full-surrender/refund amounts use different provisions. **C053, C056–C057, C061, C073–C075; S001, S012–S013.** | Payment character, starting date, partial-annuitization allocation, option exercise. | Pre-start income-first or life-contract recovery rules apply unchanged after annuitization. | The precise final §72 regulation and historical effective-date provision governing the relevant payment category. |\n\n## 5. Wholly blank evidence and audit worksheet\n\nOnly field labels are supplied. Every evidence, authority, and assessment entry is blank. No identifying fields, hypothetical entries, default outcomes, dates, amounts, or checked boxes are populated.\n\n| Audit field | Evidence / entry | Authority / version / pinpoint | Assessment / unresolved issue |\n| --- | --- | --- | --- |\n| Federal contract category |  |  |  |\n| Applicable qualification regime |  |  |  |\n| Applicable-law qualification predicate |  |  |  |\n| Selected §7702 qualification test |  |  |  |\n| Qualification continuity or failure |  |  |  |\n| Issue-date predicate |  |  |  |\n| Historical transition predicate |  |  |  |\n| Contract-year convention |  |  |  |\n| Material-change predicate |  |  |  |\n| Benefit-reduction predicate |  |  |  |\n| Reinstatement predicate |  |  |  |\n| Exchange predicate and direction |  |  |  |\n| Prior MEC or successor-exchange status |  |  |  |\n| Seven-pay determination |  |  |  |\n| Seven-pay amount-paid adjustments |  |  |  |\n| Premium-return predicate |  |  |  |\n| Investment-in-contract components |  |  |  |\n| Prior excluded distributions |  |  |  |\n| Prior taxable deemed receipts |  |  |  |\n| Transfer-for-value adjustment |  |  |  |\n| Annuity starting-date predicate |  |  |  |\n| Cash receipt characterization |  |  |  |\n| Loan receipt characterization |  |  |  |\n| Assignment / pledge / agreement characterization |  |  |  |\n| Assigned or pledged portion measurement |  |  |  |\n| Burial/funeral exception predicate |  |  |  |\n| Outstanding principal characterization |  |  |  |\n| Accrued interest characterization |  |  |  |\n| Capitalized interest characterization |  |  |  |\n| Repayment characterization |  |  |  |\n| Cash-value measurement convention |  |  |  |\n| Surrender-value measurement convention |  |  |  |\n| Complete-surrender/refund predicate |  |  |  |\n| Lapse / termination / discharge characterization |  |  |  |\n| Gross contract receipt components |  |  |  |\n| Debt application or assumption components |  |  |  |\n| Net cash reconciliation |  |  |  |\n| Prior-treatment reconciliation |  |  |  |\n| Calendar-year aggregation predicate |  |  |  |\n| Other statutory aggregation predicate |  |  |  |\n| Additional-tax inclusion base |  |  |  |\n| Taxpayer-age exception predicate |  |  |  |\n| Disability exception predicate |  |  |  |\n| Periodic-payment exception predicate |  |  |  |\n| Periodic-payment modification authority |  |  |  |\n| Separate interest-deduction provision |  |  |  |\n| Long-term-care rider/charge predicate |  |  |  |\n| Reporting provision and version |  |  |  |\n| Reporting versus withholding reconciliation |  |  |  |\n| Death-benefit boundary |  |  |  |\n| Contractual-consequence boundary |  |  |  |\n| Source legal status |  |  |  |\n| Source applicability/effective date |  |  |  |\n| Source access date |  |  |  |\n| Printed page |  |  |  |\n| Zero-based PDF index |  |  |  |\n| Actual read extent |  |  |  |\n| Authority gap |  |  |  |\n| Next permissible public-law inquiry |  |  |  |\n| Researcher self-check |  |  |  |\n\n## 6. Calculation and illustration decision\n\n**No numerical illustration or actual calculation is supplied.** The statutory percentages, dollar thresholds, dates, and periods above are legal predicates taken from the cited provisions; they are not arbitrary teaching inputs.\n\nThe missing inputs prevent a reliable numerical application: applicable statutory era, contract qualification, MEC determination and lookback, receipt character, immediately preceding statutory value, investment and prior recoveries, aggregation, debt application, taxable deemed-receipt adjustments, and any additional-tax exception. Actuarial assumptions, averaging conventions, and event-specific gross/net treatment are also not all established.\n\nThe appropriate qualitative sequence is:\n\n1. Establish the applicable contract category and statutory version.\n2. Determine whether the event is an actual receipt, deemed receipt, annuity payment, complete surrender/refund, or a different event.\n3. Apply the correct aggregation and special benefit-reduction or rider provisions.\n4. Select the proper value and investment measurements and ordering rule.\n5. Reconcile prior taxation, investment adjustments, debt, gross receipt, and net cash without double counting.\n6. Apply §72(v), if relevant, only to the resulting includible amount and only after testing its exceptions.\n7. Address interest deduction, reporting, and withholding separately.\n\n**Illustration reference E0:** no illustration, for the reasons just stated. Claim links: **C003–C005, C016–C020, C045–C070, C078–C099, C103–C113**.\n\n## 7. Granular coverage and crosswalk\n\n**Status meanings:** “Answered” means the generic rule or boundary is established by the identified read authority. “Partial” means a material public-law or version issue remains. “Unresolved” means actual application cannot be determined from the absent facts. “Excluded” means the user expressly reserved the subject or it is unnecessary to the selected comparison.\n\n| Requested item / subquestion | Status | Finding and evidence crosswalk | Missing evidence or exact next permissible inquiry |\n| --- | --- | --- | --- |\n| **1 — Complete material §72 provisions** | **Answered, selected complete provisions** | S001 read bounds; C005, C053–C086; B05–B14, B20. | Actual application unresolved; no claim of whole-§72 reading. |\n| **1 — Actual life-contract definition** | **Answered** | C002–C034; S003, S006, S014, S024; B01–B02. | Qualification facts held; targeted further published qualification guidance only. |\n| **1 — Actual MEC definition and seven-pay computation** | **Answered statutory framework** | C035–C048; S002; B03, B17. | Actual actuarial test and contract facts held. |\n| **1 — Investment and distinct value definitions** | **Answered** | C003–C005, C013, C046, C056, C058, C094; S001–S004. | Actual measurement inputs absent; no interchange of definitions. |\n| **1 — Nested benefit-reduction/material-change rules** | **Answered** | C015–C020, C038–C045, C069; S002–S003, S011. | Actual reduction/change/rider predicates held. |\n| **1 — Issue/exchange/grandfather triggers** | **Answered with specific partial issue** | C007, C028–C034, C044, C049–C052, C060, C070; S001–S003, S006, S014. | §7702(i)’s post-2020 legacy cross-reference remains partial; next inquiry is published Treasury/IRS interpretation. |\n| **1 — Aggregation** | **Answered statutory rules** | C012, C042, C070, C092, C095; B11. | Additional regulatory anti-abuse application not presumed; exact statutory grouping facts held. |\n| **1 — No uniform permanent-policy/loan/balance inference** | **Answered boundary** | C002, C035, C054–C066, comparison table. | No actual classification supplied. |\n| **2 — Non-MEC versus MEC** | **Answered** | C035, C054–C059, C070, C078–C082; S001–S002. | Application unresolved without qualification/MEC evidence. |\n| **2 — Annuity and excluded-contract comparison** | **Answered to necessary boundary** | C026, C060, C071, C073–C077, C083–C085. | Full annuity/retirement analysis excluded; B02, B20 identify permitted next inquiry. |\n| **2 — Unknown/nonqualifying category** | **Answered conditional rule** | C023–C025; S003 §7702(g); B01. | Actual failure and annual/catch-up amounts unresolved. |\n| **2 — Loan and collateral assignment/pledge** | **Answered statutory trigger** | C054–C059, C071–C072; B06–B07. | Character, affected portion, timing, and exceptions unknown. |\n| **2 — Cash distribution ordering and investment recovery** | **Answered conditional rule** | C005, C016–C020, C053–C061, C067–C075. | Receipt/start-date/aggregation inputs absent. |\n| **2 — Complete surrender/refund/maturity** | **Answered** | C061–C064; S001, S013, S016–S018. | Actual amount received and prior investment unknown. |\n| **2 — Lapse/termination/discharge and zero-cash events** | **Partial public-law coverage; unresolved application** | C064–C066; B08–B10. | Need event-specific published authority and absent event mechanics; no case or record query. |\n| **2 — Separate cash, income, liability, policy debt, and later event** | **Answered analytical distinction** | C005, C057–C058, C064–C066, C103, C107–C113. | No actual reconciliation possible. |\n| **3 — MEC additional-tax base/rate** | **Answered** | C078; S001 §72(v)(1). | Includible amount unknown; E0. |\n| **3 — Age/disability/periodic-payment exceptions** | **Answered statutory predicates** | C079–C082; S001 §§72(v)(2), (m)(7); B12. | Actual taxpayer/event evidence held. |\n| **3 — Periodic-payment modification/recapture** | **Partial** | C084, C086; S001 versus S019. | Published §72(v)-specific authority resolving instruction/statute tension not established. |\n| **3 — Necessary interest-deduction provisions** | **Answered statutory gates; application excluded/held** | C087–C099; S004–S006; B13. | Full deduction tracing, business ownership, rates, elections, and calculations held. |\n| **3 — No borrowing prohibition from deduction restriction** | **Answered boundary** | C091, C099–C100. | Contractual rights and insurance consequences excluded. |\n| **3 — No §72(p), consumer-loan, or death-benefit importation** | **Answered boundary** | C065–C066, C077, C082, C105, C112. | Other components and full death/COD regimes excluded. |\n| **4 — Necessary final regulations** | **Answered selected reading; partial original-history verification** | S012–S015; C029, C061, C073, C102. | Original §1.1035-1 issuance/effectiveness and complete old-T.D. histories not verified. |\n| **4 — Published IRS interpretation and modification status** | **Answered** | S016–S018; C062–C064. | No universal loan-lapse conclusion extrapolated from a loan-free ruling situation. |\n| **4 — Public instructions, version, fields, reporting function** | **Answered selected material body** | S019; C086, C109–C112. | Exact issuance day not established; no whole-document/form-pixel claim. |\n| **4 — Reporting/withholding authority** | **Answered boundary** | S020–S022; C106–C108, C113. | Actual obligation and full reporting rules held. |\n| **4 — Primary-source status/access/read bounds** | **Answered with disclosed gaps** | Source register, C001, source-read/failure log. | Compilation dates are not a complete later-law or judicial audit. |\n| **5 — Provision-specific comparison** | **Answered** | Section 3; C002–C113 as linked there. | All actual applications remain unresolved. |\n| **5 — At least twelve substantive branches** | **Answered: B01–B20** | Each branch contains rule, C/S links, missing evidence, adverse inference, next inquiry. | None populated with an identifying entry. |\n| **5 — Wholly blank evidence/audit worksheet** | **Answered** | Section 5. | All entry cells deliberately blank. |\n| **5 — No borrowing/surrender/lapse/replacement recommendation** | **Answered scope requirement** | C100; B16, B18. | Suitability and contractual consequences excluded. |\n| **6 — Optional mathematical illustration** | **Omitted with reason** | E0; Section 6. | Missing trigger, measurement, ordering, aggregation, and convention inputs. |\n| **6 — No actual deadline/value/deduction/tax bill** | **Answered scope requirement** | E0; no application numbers supplied. | Statutory dates and thresholds are stated only as law. |\n| **Parent holds and other A036 components** | **Excluded with reason** | C077, C100, C105, C113; B13, B15–B16. | Retirement, equity, family help, savings/asset sales, other taxes, nonfederal law, insurer practices, and full remedies/reporting remain reserved. |\n| **Independent review / acceptance** | **Not performed or claimed** | Researcher self-check below. | No component, parent, operational, or publication acceptance. |\n\n## 8. Source-read and failure log\n\nThe source register is the successful-read log: it distinguishes whole-section reads, selected complete provisions, selected instruction bodies, and parsed PDF text.\n\n| Log entry | What occurred | Treatment and remaining limit |\n| --- | --- | --- |\n| **R036-P1-F001 — Legacy OLRC routes** | Initial legacy granule-based requests for §§72, 7702A, 7702, and 264 failed. | Recovered the official versioned bodies recorded in S001–S004. Failure was not treated as absence of law. |\n| **R036-P1-F002 — Intermittent versioned-page access** | A later direct request to [https://uscode.house.gov/us/usc/119-124/t26/s72/](https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com) returned inaccessible. | Reopening the previously retrieved official source succeeded; the complete relevant §72(e) body was re-read. The failed request does not negate the successful read. |\n| **R036-P1-F003 — Current-edition redirects** | Some current OLRC routes first returned only a redirect page; certain direct version guesses also failed. | The actual “Continue” links were followed to the source bodies, including §§1031, 6047, and 807. Redirect/index text was not used as substantive law. |\n| **R036-P1-F004 — Additional §7702 regulation lead** | An attempted §1.7702-1 access did not supply a usable body. | No rule was inferred from that failure, and no proposed or unavailable text was treated as operative. The successfully read age regulation is specifically §1.7702-2. |\n| **R036-P1-F005 — Search results outside scope** | Generic searches returned some private determinations, case discussions, and provider-related material among results. | Those materials were not followed or relied on. No identifying-party, policy, account, case-record, or provider investigation was conducted. |\n| **R036-P1-F006 — Truncated retrieval output** | Some long statutory outputs were truncated. | Material sections and notes were reopened or read in bounded portions. Whole-read claims are confined to the instruments identified as whole in the source register. |\n| **R036-P1-F007 — PDF modality** | S016 and S017 were available as parsed PDF text. | All stated PDF pages were read as text. Printed pages and zero-based indexes are separately recorded. No claim of pixel or unseen scan inspection. |\n| **R036-P1-F008 — Publication metadata limits** | Exact issuance/revision days were not established for the 2025 publication and 2026 instructions; original issuance/effectiveness of §1.1035-1 was not verified. | These are explicit metadata gaps. Version headings and current codification were not substituted for original issuance/effectiveness findings. |\n| **R036-P1-F009 — Same instrument in multiple formats** | Rulings and T.D. 9287 were encountered in PDF/eCFR/IRB formats. | Formats are grouped under one source ID per instrument. They are not counted as independent corroboration. |\n| **R036-P1-F010 — Targeted unresolved-authority searches** | Generic official-source searches did not establish a complete §72(v)-specific recapture authority or one exhaustive rule covering every zero-cash lapse and capitalized-interest configuration. | The gaps remain C065–C066 and C086. A failed or unproductive search is not a finding that no law exists. |\n\n## 9. Explicit gaps and limits\n\n1. **Actual application is unresolved throughout.** The contract, role, qualification, issue/change/exchange, MEC, investment, value, debt, interest, premium, distribution, lapse, surrender, death, reporting, and return facts remain held. No actual or invented policy was substituted.\n2. **The lapse/discharge boundary is not reduced to a universal formula.** The full-surrender statute, loan/pledge deeming statute, and Publication 525 explanation establish necessary distinctions. They do not support declaring that every lapse causes a specified amount of income, every balance is forgiven, or every zero-cash event is nontaxable.\n3. **The §72(v) periodic-payment modification issue remains open.** The reporting instruction’s reference to a five-year modification rule has been recorded, but a substantive MEC-specific recapture rule, base, and interest computation have not been established from the authorities read.\n4. **Certain qualification subfields remain conditional rather than certified.** These include detailed variable-contract diversification, incorporated long-term-care standards, regulatory allowances expressly conditioned on regulations, and the legacy §7702(i) rate cross-reference after the 2020 amendment.\n5. **Historical statutory text is not present relief.** The report separates current codified rules, historical grandfather provisions, expired transition windows, and later-effective amendments. No proposed rule is used as operative authority, and no withdrawn instrument is relied on.\n6. **Full deductions, reporting, penalties, remedies, and current judicial history remain reserved.** The selected deduction and reporting provisions establish boundaries necessary to this component; they do not resolve the parent’s broader held subjects.\n\n## 10. Researcher self-check — not independent review\n\n- The actual statutory definitions precede application of the shorthand **MEC**, investment, and statutory cash-value measures.\n- Non-MEC life treatment, MEC treatment, annuity treatment, and qualification failure are separately traced.\n- Cash delivery, deemed receipt, gross-income inclusion, investment adjustment, outstanding debt, debt settlement, withholding, and final tax liability are not equated.\n- The distinct seven-year, fifteen-year, five-year, two-year, contract-year, and calendar-year provisions are linked to their own triggers.\n- The burial qualification rule, MEC burial assignment exception, small-benefit seven-pay adjustment, and long-term-care rider rules are kept separate.\n- No retirement-plan loan rule or report was used as a foundation; the limited §72(p) references identify the boundary only.\n- No actual tax calculation, deadline, recommendation, contract right, insurer practice, personal record, or identifying entry was supplied.\n- The source register discloses legal status, version, read extent, PDF modality, access date, and the outstanding authority gaps.\n\nThis is the same researcher’s self-check. It is **not independent review, component acceptance, parent acceptance, operational acceptance, or publication acceptance**.\n\nEND R036 PASS-01\n\n","tables":[{"headers":["Source ID","Issuer, instrument, and complete literal HTTPS URL","Version, legal status, and effectiveness","Actual read bounds, precise pinpoints, and limits"],"index":0,"links":[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t26/s72/"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"uscode.house.gov\n+2"},{"href":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/"},{"href":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t26/s7702/"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com","text":"uscode.house.gov\n+1"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s264/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s163/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s163/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s163/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s101/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s101/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s101/?utm_source=chatgpt.com","text":"uscode.house.gov\n+2"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s1035/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s1035/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s1035/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s1031/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s1031/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s1031/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s357/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s357/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s357/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s817/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s817/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s817/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s7702B/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s7702B/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s7702B/?utm_source=chatgpt.com","text":"uscode.house.gov\n+1"},{"href":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2","text":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2"},{"href":"https://www.ecfr.gov/current/title-26/section-1.72-2?utm_source=chatgpt.com","text":"ecfr.gov\n+1"},{"href":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11","text":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11"},{"href":"https://www.ecfr.gov/current/title-26/section-1.72-11?utm_source=chatgpt.com","text":"ecfr.gov\n+2"},{"href":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2","text":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2"},{"href":"https://www.irs.gov/irb/2006-46_IRB?utm_source=chatgpt.com","text":"https://www.irs.gov/irb/2006-46_IRB"},{"href":"https://www.ecfr.gov/current/title-26/section-1.7702-2?utm_source=chatgpt.com","text":"ecfr.gov\n+1"},{"href":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1","text":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1"},{"href":"https://www.ecfr.gov/current/title-26/section-1.1035-1?utm_source=chatgpt.com","text":"ecfr.gov"},{"href":"https://www.irs.gov/pub/irs-drop/rr-09-13.pdf?utm_source=chatgpt.com","text":"https://www.irs.gov/pub/irs-drop/rr-09-13.pdf"},{"href":"https://www.irs.gov/irb/2009-21_IRB?utm_source=chatgpt.com","text":"https://www.irs.gov/irb/2009-21_IRB"},{"href":"https://www.irs.gov/pub/irs-drop/rr-09-13.pdf?utm_source=chatgpt.com","text":"irs.gov\n+1"},{"href":"https://www.irs.gov/pub/irs-drop/rr-20-05.pdf?utm_source=chatgpt.com","text":"https://www.irs.gov/pub/irs-drop/rr-20-05.pdf"},{"href":"https://www.irs.gov/irb/2020-09_IRB?utm_source=chatgpt.com","text":"https://www.irs.gov/irb/2020-09_IRB"},{"href":"https://www.irs.gov/pub/irs-drop/rr-20-05.pdf?utm_source=chatgpt.com","text":"irs.gov\n+1"},{"href":"https://www.irs.gov/publications/p525?utm_source=chatgpt.com","text":"https://www.irs.gov/publications/p525"},{"href":"https://www.irs.gov/publications/p525?utm_source=chatgpt.com","text":"Internal Revenue Service"},{"href":"https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com","text":"https://www.irs.gov/instructions/i1099r"},{"href":"https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com","text":"Internal Revenue Service\n+3"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s31/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s31/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s31/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s6047/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s6047/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s6047/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s3405/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s3405/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s3405/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/currency.html?utm_source=chatgpt.com","text":"https://uscode.house.gov/currency.html"},{"href":"https://uscode.house.gov/classification/tables.html?utm_source=chatgpt.com","text":"https://uscode.house.gov/classification/tables.html"},{"href":"https://uscode.house.gov/classification/tbl119cd_2nd.html?utm_source=chatgpt.com","text":"https://uscode.house.gov/classification/tbl119cd_2nd.html"},{"href":"https://uscode.house.gov/currency.html?utm_source=chatgpt.com","text":"US Code\n+2"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s807/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t26/s807/"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s807/?utm_source=chatgpt.com","text":"uscode.house.gov"}],"row_links":[[],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t26/s72/"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"uscode.house.gov\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/"},{"href":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t26/s7702/"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com","text":"uscode.house.gov\n+1"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s264/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s163/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s163/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s163/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s101/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s101/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s101/?utm_source=chatgpt.com","text":"uscode.house.gov\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s1035/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s1035/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s1035/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s1031/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s1031/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s1031/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s357/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s357/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s357/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s817/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s817/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s817/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s7702B/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s7702B/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s7702B/?utm_source=chatgpt.com","text":"uscode.house.gov\n+1"}],[{"href":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2","text":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2"},{"href":"https://www.ecfr.gov/current/title-26/section-1.72-2?utm_source=chatgpt.com","text":"ecfr.gov\n+1"}],[{"href":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11","text":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11"},{"href":"https://www.ecfr.gov/current/title-26/section-1.72-11?utm_source=chatgpt.com","text":"ecfr.gov\n+2"}],[{"href":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2","text":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2"},{"href":"https://www.irs.gov/irb/2006-46_IRB?utm_source=chatgpt.com","text":"https://www.irs.gov/irb/2006-46_IRB"},{"href":"https://www.ecfr.gov/current/title-26/section-1.7702-2?utm_source=chatgpt.com","text":"ecfr.gov\n+1"}],[{"href":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1","text":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1"},{"href":"https://www.ecfr.gov/current/title-26/section-1.1035-1?utm_source=chatgpt.com","text":"ecfr.gov"}],[{"href":"https://www.irs.gov/pub/irs-drop/rr-09-13.pdf?utm_source=chatgpt.com","text":"https://www.irs.gov/pub/irs-drop/rr-09-13.pdf"},{"href":"https://www.irs.gov/irb/2009-21_IRB?utm_source=chatgpt.com","text":"https://www.irs.gov/irb/2009-21_IRB"},{"href":"https://www.irs.gov/pub/irs-drop/rr-09-13.pdf?utm_source=chatgpt.com","text":"irs.gov\n+1"}],[{"href":"https://www.irs.gov/pub/irs-drop/rr-20-05.pdf?utm_source=chatgpt.com","text":"https://www.irs.gov/pub/irs-drop/rr-20-05.pdf"},{"href":"https://www.irs.gov/irb/2020-09_IRB?utm_source=chatgpt.com","text":"https://www.irs.gov/irb/2020-09_IRB"},{"href":"https://www.irs.gov/pub/irs-drop/rr-20-05.pdf?utm_source=chatgpt.com","text":"irs.gov\n+1"}],[{"href":"https://www.irs.gov/publications/p525?utm_source=chatgpt.com","text":"https://www.irs.gov/publications/p525"},{"href":"https://www.irs.gov/publications/p525?utm_source=chatgpt.com","text":"Internal Revenue Service"}],[{"href":"https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com","text":"https://www.irs.gov/instructions/i1099r"},{"href":"https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com","text":"Internal Revenue Service\n+3"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s31/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s31/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s31/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s6047/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s6047/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s6047/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s3405/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-134/t26/s3405/"},{"href":"https://uscode.house.gov/us/usc/119-134/t26/s3405/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[{"href":"https://uscode.house.gov/currency.html?utm_source=chatgpt.com","text":"https://uscode.house.gov/currency.html"},{"href":"https://uscode.house.gov/classification/tables.html?utm_source=chatgpt.com","text":"https://uscode.house.gov/classification/tables.html"},{"href":"https://uscode.house.gov/classification/tbl119cd_2nd.html?utm_source=chatgpt.com","text":"https://uscode.house.gov/classification/tbl119cd_2nd.html"},{"href":"https://uscode.house.gov/currency.html?utm_source=chatgpt.com","text":"US Code\n+2"}],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s807/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t26/s807/"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s807/?utm_source=chatgpt.com","text":"uscode.house.gov"}]],"rows":[["Source ID","Issuer, instrument, and complete literal HTTPS URL","Version, legal status, and effectiveness","Actual read bounds, precise pinpoints, and limits"],["R036-P1-S001","Congress; OLRC, 26 U.S.C. §72, Annuities; certain proceeds of endowment and life insurance contracts. https://uscode.house.gov/us/usc/119-124/t26/s72/","Retrieved text through P.L. 119-124, October 15, 2026. Statute as amended; applicable historical and transition provisions must be selected separately.","Read complete (a)–(c), (e)(1)–(12), (f), (g), (h), (j), (l), (m)(7), (q), (u), and (v); selected (p)(1), (p)(5), and (s)(6)(B) for boundaries only. Read material amendment/effective-date notes concerning 1982, 1984, 1986, 1988–1989, 1996, 2006, 2010, and the relevant 2022 annuity amendment. Not a whole-§72 or whole-notes read. \nuscode.house.gov\n+2"],["R036-P1-S002","Congress; OLRC, 26 U.S.C. §7702A, Modified endowment contract defined. https://uscode.house.gov/us/usc/119-121/t26/s7702A/","Retrieved text through P.L. 119-121, October 9, 2026. Added by P.L. 100-647, §5012(c), November 10, 1988; substantive applicability generally begins with contracts entered into on or after June 21, 1988, subject to the reproduced transitions.","Whole section (a)–(e), source credit, amendments, effective-date notes, and 2002 construction note read. Particularly §§7702A(a), (c)(2)–(6), (d), (e), and P.L. 100-647 §5012(e), as amended. \nuscode.house.gov"],["R036-P1-S003","Congress; OLRC, 26 U.S.C. §7702, Life insurance contract defined. https://uscode.house.gov/us/usc/119-124/t26/s7702/","Retrieved text through P.L. 119-124, October 15, 2026. Added July 18, 1984. The 2020 interest-assumption amendments apply to contracts issued after December 31, 2020. Other applicability rules are detailed below.","Whole section (a)–(k), source credit, amendments, and displayed notes read. Material pinpoints: (b)–(f) qualification and measurements; (f)(7) benefit-reduction recapture; (g) failure; (i)–(j) special categories; P.L. 98-369 §221(d), P.L. 116-260 div. EE §205(e). \nuscode.house.gov\n+1"],["R036-P1-S004","Congress; OLRC, 26 U.S.C. §264, Certain amounts paid in connection with insurance contracts. https://uscode.house.gov/us/usc/119-134/t26/s264/","Retrieved text through P.L. 119-134, October 20, 2026. Current statutory body includes separate purchase-date rules and historical transition provisions.","Whole section (a)–(f), source credit, amendments, and displayed notes read. §§264(a)(2)–(4), (c)–(f), and P.L. 104-191 §501(c)–(d) are material. Full business-deduction application remains excluded. \nuscode.house.gov"],["R036-P1-S005","Congress; OLRC, 26 U.S.C. §163, Interest. https://uscode.house.gov/us/usc/119-134/t26/s163/","Retrieved text through P.L. 119-134, October 20, 2026.","Selected (a), (h)(1), and (h)(2) read for the separate deduction gate. Not a complete §163, investment-interest, business-interest, residence-interest, or other personal-interest-exception analysis. \nuscode.house.gov"],["R036-P1-S006","Congress; OLRC, 26 U.S.C. §101, Certain death benefits. https://uscode.house.gov/us/usc/119-134/t26/s101/","Retrieved text through P.L. 119-134, October 20, 2026.","Read (a)–(f), with (f)’s concluding clauses separately completed. Used (a), (c), and (d) only as death-benefit boundaries; read (f) completely for pre-1985 flexible-premium predicates. Read P.L. 105-34 §1084(d) note concerning post-June 8, 1997 contracts and material changes. Not a complete death-benefit or employer-owned-insurance analysis. \nuscode.house.gov\n+2"],["R036-P1-S007","Congress; OLRC, 26 U.S.C. §1035, Certain exchanges of insurance policies. https://uscode.house.gov/us/usc/119-134/t26/s1035/","Retrieved text through P.L. 119-134, October 20, 2026. Long-term-care exchange amendments apply to exchanges after December 31, 2009.","Whole (a)–(d), source/amendment/effective-date notes read. Foreign-person regulatory limitation identified but not developed. \nuscode.house.gov"],["R036-P1-S008","Congress; OLRC, 26 U.S.C. §1031, Exchange of real property held for productive use or investment, incorporated provisions. https://uscode.house.gov/us/usc/119-134/t26/s1031/","Retrieved text through P.L. 119-134, October 20, 2026.","Read complete (b)–(d) because §1035(d) incorporates them. No real-estate exchange timing rules applied. Not a whole-section/history read. \nuscode.house.gov"],["R036-P1-S009","Congress; OLRC, 26 U.S.C. §357, Assumption of liability, incorporated definition. https://uscode.house.gov/us/usc/119-134/t26/s357/","Retrieved text through P.L. 119-134, October 20, 2026.","Read complete (d)(1)–(3) for the liability-assumption definition incorporated by §1031(d). Corporate-transfer treatment and complete historical applicability not investigated. \nuscode.house.gov"],["R036-P1-S010","Congress; OLRC, 26 U.S.C. §817, Treatment of variable contracts. https://uscode.house.gov/us/usc/119-134/t26/s817/","Retrieved text through P.L. 119-134, October 20, 2026.","Read complete (d) and (h) for variable-contract and diversification boundaries. Treas. Reg. §1.817-5 and underlying asset qualification were not comprehensively investigated. \nuscode.house.gov"],["R036-P1-S011","Congress; OLRC, 26 U.S.C. §7702B, Treatment of qualified long-term care insurance. https://uscode.house.gov/us/usc/119-134/t26/s7702B/","Retrieved text through P.L. 119-134, October 20, 2026. Includes 1996 enactment and 2006 coordination notes.","Read (b), (c), (e), (g) and material displayed notes, including P.L. 104-191 §321(f)(4). No medical-status determination, state-law qualification investigation, or complete reading of incorporated insurance model standards. \nuscode.house.gov\n+1"],["R036-P1-S012","Treasury; eCFR, Treas. Reg. §1.72-2, Applicability of section 72. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2","Codified final regulation; retrieved eCFR status through October 22, 2026. Source history includes T.D. 6500, November 26, 1960; T.D. 6497, October 20, 1960; T.D. 6885, June 2, 1966.","Read (a)(1)–(2), (b)(1)–(3) and source note. Used for annuity/nonannuity boundary, subject to later statutes. Original Treasury-decision preambles and all historical effectiveness provisions not read. \necfr.gov\n+1"],["R036-P1-S013","Treasury; eCFR, Treas. Reg. §1.72-11, Amounts not received as annuity payments. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11","Codified final regulation; retrieved status through October 16, 2026. Source history includes T.D. 6500, November 26, 1960; T.D. 6885, June 2, 1966; T.D. 8115, December 19, 1986.","Whole (a)–(h) and source note read. Material surrender provision (d)(1)–(2). Historical caps and obsolete cross-references were not treated as overriding amended §72. Full original-decision effectiveness audit not performed. \necfr.gov\n+2"],["R036-P1-S014","Treasury, Treas. Reg. §1.7702-2, Attained age of the insured under a life insurance contract; T.D. 9287. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2. Same instrument in https://www.irs.gov/irb/2006-46_IRB.","Final T.D. 9287, September 13, 2006, 71 FR 53970; effective that day, with distinct contract applicability under paragraph (f). First retrieved eCFR snapshot through October 13, 2026. IRB publication November 13, 2006.","Whole regulation (a)–(f), including examples and applicability, read. Selected T.D. preamble/version material read in IRB, not the whole bulletin. These formats are one instrument, not independent corroboration. \necfr.gov\n+1"],["R036-P1-S015","Treasury; eCFR, Treas. Reg. §1.1035-1, Certain exchanges of insurance policies. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1","Codified final regulation; retrieved status through October 23, 2026. Original issuance/effective date not verified in the retrieved section.","Whole section text read. Same-insured/same-obligee and money/other-property provisions used. Its older exchange-category wording was read with current §1035, including later long-term-care amendments. \necfr.gov"],["R036-P1-S016","IRS, Rev. Rul. 2009-13. https://www.irs.gov/pub/irs-drop/rr-09-13.pdf. Published in https://www.irs.gov/irb/2009-21_IRB.","Published IRS interpretation, 2009-21 I.R.B. 1029, May 26, 2009. Modified by S017; not relied on as an unmodified instrument.","All 12 PDF pages read as parsed text, indexes 0–11. Surrender analysis: printed pp. 3–5 / indexes 2–4; holding 1: printed p. 11 / index 10. Its surrender situation has no outstanding loan or prior withdrawals. No PDF-pixel inspection claimed; no case opinions investigated. \nirs.gov\n+1"],["R036-P1-S017","IRS, Rev. Rul. 2020-05. https://www.irs.gov/pub/irs-drop/rr-20-05.pdf. Published in https://www.irs.gov/irb/2020-09_IRB.","Published IRS interpretation, 2020-9 I.R.B. 454, February 24, 2020. Its stated effective date is transactions on or after August 26, 2009.","All six PDF pages read as parsed text, indexes 0–5. Material modification discussion printed pp. 4–5 / indexes 3–4; effect on other documents and effective date printed p. 6 / index 5. Used to establish S016’s modified status, not to regenerate an asset-sale component. No pixel inspection. \nirs.gov\n+1"],["R036-P1-S018","IRS, Publication 525 (2025), Taxable and Nontaxable Income. https://www.irs.gov/publications/p525","Public explanatory publication, 2025 version; exact original issuance/revision day not established. It is not a statute or final regulation.","Selected “Life Insurance Proceeds,” especially complete “Surrender of policy for cash” paragraph, read. Not the whole publication. Its simplified treatment of unrepaid loans is qualified below; it does not establish all lapse scenarios. \nInternal Revenue Service"],["R036-P1-S019","IRS, Instructions for Forms 1099-R and 5498 (2026). https://www.irs.gov/instructions/i1099r","Public reporting instructions, 2026 version; exact issuance/revision day not established. A tax-year heading is not a substantive effective-date finding.","Read material body: life-insurance/annuity/endowment reporting; §1035 exchanges; boxes 1, 2a, 2b, 4, 5, 7a; relevant distribution-code entries and notes. Not whole instructions; no blank-form PDF or pixels inspected; no form completed. The §72(v) periodic-payment coding issue is explicitly unresolved below. \nInternal Revenue Service\n+3"],["R036-P1-S020","Congress; OLRC, 26 U.S.C. §31, Tax withheld on wages, incorporated credit rule. https://uscode.house.gov/us/usc/119-134/t26/s31/","Retrieved text through P.L. 119-134, October 20, 2026.","Complete (a)(1)–(2) read for crediting chapter 24 withholding. Not a return or tax-payment calculation. \nuscode.house.gov"],["R036-P1-S021","Congress; OLRC, 26 U.S.C. §6047, Returns relating to certain trusts and annuity plans. https://uscode.house.gov/us/usc/119-134/t26/s6047/","Retrieved text through P.L. 119-134, October 20, 2026.","Selected complete (d)(1)–(2), (g), (h) and relevant source/amendment notes read. §6047(d)’s issuer reporting rule and §6050Y coordination identified; complete reporting obligations excluded. \nuscode.house.gov"],["R036-P1-S022","Congress; OLRC, 26 U.S.C. §3405, Special rules for pensions, annuities, and certain other deferred income. https://uscode.house.gov/us/usc/119-134/t26/s3405/","Retrieved text through P.L. 119-134, October 20, 2026.","Read (a)–(e)(13). Relied on (d), (e)(1), (e)(6), and (e)(8) to distinguish reporting/withholding classification, payor duties, cash limitations, and substantive income treatment. No full withholding determination or rate calculation. \nuscode.house.gov"],["R036-P1-S023","OLRC, Currency and Updating; Classification Tables; 2026 classification table. https://uscode.house.gov/currency.html; https://uscode.house.gov/classification/tables.html; https://uscode.house.gov/classification/tbl119cd_2nd.html","Publisher currency and classification metadata; not substantive tax authority.","Currency and table-explanation pages read; 2026 table header and entire Title 26 block read. Not the entire classification table or a full session-law audit. \nUS Code\n+2"],["R036-P1-S024","Congress; OLRC, 26 U.S.C. §807 notes, P.L. 115-97 §13517(c). https://uscode.house.gov/us/usc/119-124/t26/s807/","Retrieved text through P.L. 119-124, October 15, 2026. Enactment December 22, 2017; specified amendments apply to taxable years beginning after December 31, 2017.","Read complete §13517(c)(1)–(3) effective-date, transition, and transition-relief note. Not whole §807. The reserve transition was not imported into policyholder loan taxation. \nuscode.house.gov"]]},{"headers":["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],"index":1,"links":[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com","text":"uscode.house.gov"}],"row_links":[[],[],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[],[],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[],[],[],[],[],[],[],[],[],[],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],["R036-P1-C001","The retrieved statutory versions and targeted classification check support the version statements in the source register. They do not establish that every later enactment, judicial development, or original regulatory effective-date instrument was audited.","S001–S024, their stated currency/read bounds; S023, currency page and 2026 Title 26 classification block."],["R036-P1-C002","Under the generally applicable §7702 definition, a life-insurance contract must be life insurance under applicable law and satisfy either the cash-value-accumulation test or both the guideline-premium requirements and cash-value corridor. A product label does not establish these elements. The church-plan exception is separately addressed in C027.","S003, §7702(a)(1)–(2), (j). \nuscode.house.gov"],["R036-P1-C003","For §7702, “cash surrender value” means cash value determined without regard to a surrender charge, policy loan, or reasonable termination dividends. Thus this statutory measurement can differ from cash deliverable after charges and debt offsets.","S003, §7702(f)(2)(A). This is a section-specific definition, not a universal definition for every tax provision or contract."],["R036-P1-C004","For §7702, “net surrender value” takes surrender charges into account but disregards policy loans. It is therefore distinct from both C003’s measure and net cash actually paid.","S003, §7702(f)(2)(B)."],["R036-P1-C005","For §72(e), investment in the contract on a date is aggregate premiums or other consideration paid before that date, reduced by prior amounts received to the extent excludable under the subtitle or prior income-tax laws. The specific adjustments in C058, C068, and C072 must also be considered. “Basis” is not assumed to equal premiums, account value, or loan balance.","S001, §72(e)(6), (e)(4)(A), (e)(11), (g). \nuscode.house.gov"],["R036-P1-C006","The cash-value-accumulation test requires contract terms preventing cash surrender value at any time from exceeding the net single premium needed then to fund future benefits. Computation uses the greater of the applicable accumulation-test minimum rate or guaranteed issue rates, the specified mortality/additional-benefit charge rules, and the specified current/future-benefit assumptions.","S003, §7702(b)(1)–(2), incorporating (c)(3)(B)(i)–(ii), (e)(1)(A), (D)."],["R036-P1-C007","For contracts issued after December 31, 2020, the accumulation-test minimum is the lesser of 4% and the statutory insurance interest rate at issue; the guideline-premium minimum is that accumulation minimum plus two percentage points. The insurance interest rate is the lesser of the specified valuation and federal-rate measures for the adjustment year, or latest adjustment year. The federal-rate measure averages the prescribed 60 monthly mid-term rates, annually compounded, and rounds to the nearest whole percentage point. The statutory 2% transition begins January 1, 2021 and ends before the first adjustment year after 2021; it is not proof of a universal 2026 rate.","S003, §7702(b)(3), (c)(3)(E), (f)(11)(A)–(E); P.L. 116-260 div. EE §205(e). No rate series or actuarial calculation performed."],["R036-P1-C008","Under the guideline-premium route, cumulative premiums paid cannot exceed the guideline-premium limitation at any time. That limitation is the greater of the guideline single premium or the sum of guideline level premiums to that date.","S003, §7702(c)(1)–(2)."],["R036-P1-C009","The guideline single premium is determined at issue, except for required adjustments, using the statutory mortality, reasonably expected charge, and interest assumptions. An unspecified charge is zero for this computation; industry experience substitutes for insufficient company experience only to the extent provided by regulations. Guideline level premiums run over a period not ending before insured age 95, using the accumulation minimum instead of the higher guideline minimum. Prevailing tables and the statutory three-year table-transition option are separately relevant.","S003, §7702(c)(3)–(4), (f)(10). Current mortality clause uses the statutory alternatives in (c)(3)(B)(i); no actual table or charge assumption established."],["R036-P1-C010","Under the corridor route, the death benefit must at all times be at least the applicable percentage of cash surrender value. The percentage uses attained age at the beginning of the contract year and decreases ratably for each full year within the statutory bands reproduced immediately below.","S003, §7702(d)(1)–(2); age rules in S014. These are qualification ratios, not income-tax rates or borrowing limits."],["R036-P1-C011","Except for the corridor calculation, §7702’s general assumptions deem death and qualified additional benefits nonincreasing, maturity between insured ages 95 and 100, death benefits continuing to that deemed maturity, and endowment benefits—including maturity cash surrender value—not exceeding the least death benefit. Specified death-benefit increases may be recognized to preserve the excess over cash surrender value; the cash-value-accumulation alternative requires the stated net-level-reserve test and premium period not ending before age 95.","S003, §7702(e)(1), (e)(2)(A)–(B)."],["R036-P1-C012","A separate burial/funeral qualification rule permits specified increases for cash-value-accumulation testing only if initial death benefit is at most $5,000, maximum death benefit at most $25,000, annual fixed predetermined increase is at most 10% of initial benefit or 8% of preceding-year benefit, and the purchase is for the specified burial/prearranged-funeral expenses. Initial death benefit aggregates all contracts issued to the same owner. This rule is excluded from the MEC seven-pay computational cross-reference.","S003, §7702(e)(2)(C); S002, §7702A(c)(1)(B). The burial-increase amendment applies to contracts entered into after October 22, 1986, per S003’s note."],["R036-P1-C013","§7702 “premiums paid” is its own measure: premiums less specified nontaxable §72(e) amounts, specified excess-premium distributions, and other amounts prescribed by regulations. A premium portion returned with interest to comply with the guideline requirement within 60 days after the contract year reduces premiums for that year, excluding the interest; the returned interest is income.","S003, §7702(f)(1)(A)–(C). This is not automatically the same measure as §72 investment or §7702A “amount paid.”"],["R036-P1-C014","A premium otherwise exceeding the guideline limit is disregarded for that limit only to the extent necessary to prevent termination through the end of the contract year, and only if the contract has no cash surrender value at the end of the extension period.","S003, §7702(f)(6). This is not a general excess-premium permission or loan exclusion."],["R036-P1-C015","An unreflected change in benefits or other terms requires proper adjustments in future §7702 determinations. A §7702 adjustment and a §7702A material change are related inquiries governed by different text.","S003, §7702(f)(7)(A); compare S002, §7702A(c)(3)."],["R036-P1-C016","If an unreflected change reduces benefits during the 15-year period beginning on issue, and a cash distribution results, §72 applies without §72(e)(5) up to the applicable recapture ceiling. Thus a qualifying contract outside the MEC rules can have a distribution for which the ordinary §72(e)(5) treatment is displaced.","S003, §7702(f)(7)(B). The ceiling is not itself a declaration that its entire amount is taxable. \nuscode.house.gov"],["R036-P1-C017","For a cash-value-accumulation contract and a reduction within the first five years, the recapture ceiling is the excess of cash surrender value immediately before reduction over the net single premium immediately afterward.","S003, §7702(f)(7)(C)(i)."],["R036-P1-C018","For a guideline-premium contract and a reduction within the first five years, the ceiling is the greater of: premiums before reduction exceeding the adjusted guideline limit; or cash surrender value before reduction exceeding the post-reduction cash-value corridor.","S003, §7702(f)(7)(C)(ii)(I)–(II)."],["R036-P1-C019","For a reduction after the first five years but within the first fifteen, the ceiling is the excess of pre-reduction cash surrender value over the post-reduction corridor, whether or not the contract otherwise uses that corridor test.","S003, §7702(f)(7)(D)."],["R036-P1-C020","The benefit-reduction rule also addresses anticipatory distributions. A distribution reducing cash surrender value and made within two years before a benefit reduction is statutorily treated as anticipatory; the ceiling provisions require appropriate adjustments.","S003, §7702(f)(7)(E), including its regulatory direction."],["R036-P1-C021","Qualification failure is not automatically cured. The Secretary may waive failure only if the taxpayer establishes reasonable error and reasonable remedial steps to the Secretary’s satisfaction.","S003, §7702(f)(8). No waiver, closing agreement, or request is assumed or pursued."],["R036-P1-C022","Variable contracts require additional classification checks. §7702 testing occurs whenever death benefits change and at least once each 12-month period. §817 defines variable contracts and imposes a diversification condition, subject to its exceptions and regulatory rules. A “variable life” label alone does not establish qualification.","S003, §7702(f)(9); S010, §817(d), (h). Detailed diversification application remains partial because §1.817-5 and actual investments are outside this completed reading."],["R036-P1-C023","A contract that is life insurance under applicable law but fails §7702(a) can produce annual ordinary income under §7702(g). The statutory annual measure is the excess of the increase in net surrender value plus the cost of protection over premiums paid. Protection cost is the lesser of the specified regulatory uniform-premium measure, using five-year age brackets, or stated mortality charge.","S003, §7702(g)(1)(A), (B), (D). No annual amount established."],["R036-P1-C024","If such a contract ceases to qualify during a year, income on the contract for all prior taxable years is treated as received or accrued in the cessation year under the statutory catch-up rule.","S003, §7702(g)(1)(C). This is a qualification-failure rule, not a universal lapse or loan-balance rule."],["R036-P1-C025","For a state-law life contract failing §7702(a), only death proceeds exceeding net surrender value receive the specified deemed-life-insurance treatment under §7702(g)(2). The contract nevertheless remains an insurance contract for the Code under (g)(3). Failure does not automatically make it a MEC or an ordinary annuity.","S003, §7702(g)(2)–(3). Full beneficiary treatment remains unestablished."],["R036-P1-C026","Section 7702 extends its qualification/failure rules to applicable-law endowment contracts and separately defines qualifying endowment contracts for the Code. Section 72 also includes certain face-amount certificates issued after December 31, 1954 within its endowment-contract terminology. These provisions prevent classification solely from a product title.","S003, §7702(h); S001, §72(l). The incorporated securities-law certificate definition was not needed to classify an actual instrument and was not independently developed."],["R036-P1-C027","The applicable-law limb of §7702(a) is waived for the specified church-provided death-benefit arrangements for employees and beneficiaries, directly or through the specified organizations. The other federal qualification requirements are not thereby universally waived.","S003, §7702(j)(1)–(3). No employment, church, or organizational facts supplied; application excluded."],["R036-P1-C028","The printed §7702(i) qualified-20-pay rule requires at least 20 nondecreasing annual premiums and an existing plan filed before September 28, 1983, on file in the appropriate state. Its text substitutes 3% for 4% in §7702(b)(2). Because the 2020 amendment changed that subsection’s rate wording, a modern application of this legacy cross-reference is not resolved here.","S003, §7702(i); P.L. 98-369 §221(d)(3); 2020 amendment notes. Annual rather than monthly excess-interest crediting does not itself defeat the specified pre-1983-plan predicate."],["R036-P1-C029","Final §1.7702-2 governs attained age for specified §7702 tests: actual birthday age or a consistently used contract age within 12 months of actual age, changing annually. First-to-die contracts use the oldest insured; last-to-die contracts generally use the youngest, with the prescribed youngest-surviving rule when both cash-value and future-mortality terms change at death. It applies to contracts issued after December 31, 2008, or on/after October 1, 2007 using the specified 2001 tables; earlier use is permitted only under its consistency condition.","S014, §1.7702-2(a)–(f). This actuarial insured-age rule does not establish the taxpayer-age exception under §72(v)."],["R036-P1-C030","Section 7702 generally applies to contracts issued after December 31, 1984, in taxable years ending afterward. It also reaches specified increasing-death-benefit contracts issued after June 30, 1984 with funding faster than ten-year level premiums, subject to C031–C032. For a master contract, the relevant issue date for an insured is first coverage.","S003, P.L. 98-369 §221(d)(1), (2)(A), (5)."],["R036-P1-C031","The early-1984 application has three alternative exceptions: a contract meeting the specified §101(f) test; a nonflexible-premium contract meeting the modified §7702 test using 3% and the specified latest-maturity/20-year/age-95 assumption; or the specified periodically adjusted level-premium arrangement using at least 3%, with a comparable death-benefit adjustment allowed at the insured’s option.","S003, P.L. 98-369 §221(d)(2)(B)(i)–(iii). These are historical predicates, not a blanket pre-1985 exemption."],["R036-P1-C032","A further 1984 transition substitutes September 30, 1984 for June 30 when the contract meets the specified modified §7702 test, disregards the specified mortality charges and initial excess-interest guarantees in determining guaranteed rates, and never exceeds the prescribed net-single-premium value. That value uses 3%, the specified 1958 tables, and a level death benefit. A flexible-premium contract issued during 1984 that meets §7702 is treated as meeting §101(f).","S003, P.L. 98-369 §221(d)(2)(C); §221(b)(3), as added in 1986."],["R036-P1-C033","Section 101(f)’s pre-1985 flexible-premium category has its own predicates. It concerns premiums not fixed as to both timing and amount, excluding a state-law annuity portion other than a settlement option. Its death-payment condition requires either the guideline-limit/corridor route or the cash-value/net-single-premium route. Its corridor begins at 140% through age 40, decreases one percentage point per later year, and bottoms at 105%. Its guideline assumptions use guaranteed charges and the greater of 6% or guaranteed rates, with 4% for level premiums; its net-single-premium interest floor is 4%, or 3% for issuance before July 1, 1983. It has distinct maturity, benefit-change, qualified-additional-benefit, premium-refund-within-60-days, necessary-premium, and reasonable-error provisions. These historical tests cannot be replaced by a current product label.","S006, §101(f)(1)–(3), read completely. Cash value disregards surrender charges and policy loans; net-single-premium mortality uses the specified guaranteed/all-state-table predicate; maturity and endowment assumptions are those in (2)(D), (3)(G). No actual death exclusion or actuarial determination made."],["R036-P1-C034","The 2017 mortality/table amendments have an effective-date rule for taxable years beginning after December 31, 2017. The accompanying reserve transition and eight-year reserve adjustment concern the specified reserve provisions; they are not a policyholder loan-income spreading rule.","S003, amendment/effectiveness notes; S024, P.L. 115-97 §13517(c)(1)–(3)."]]},{"headers":["Insured attained-age band, beginning of contract year","Applicable percentage, from → to"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Insured attained-age band, beginning of contract year","Applicable percentage, from → to"],["More than 0, not more than 40","250% → 250%"],["More than 40, not more than 45","250% → 215%"],["More than 45, not more than 50","215% → 185%"],["More than 50, not more than 55","185% → 150%"],["More than 55, not more than 60","150% → 130%"],["More than 60, not more than 65","130% → 120%"],["More than 65, not more than 70","120% → 115%"],["More than 70, not more than 75","115% → 105%"],["More than 75, not more than 90","105% → 105%"],["More than 90, not more than 95","105% → 100%"]]},{"headers":["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],"index":3,"links":[{"href":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com","text":"uscode.house.gov"}],"row_links":[[],[{"href":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],["R036-P1-C035","A modified endowment contract—MEC—must first meet §7702. It is a contract entered into on or after June 21, 1988 that fails the seven-pay test, or a qualifying contract received in exchange for such a MEC or a successor exchange contract. Failure of §7702 is not the MEC definition.","S002, §7702A(a)(1)–(2). \nuscode.house.gov"],["R036-P1-C036","The seven-pay test fails if, at any time during the first seven contract years, accumulated amount paid exceeds the cumulative net level premiums that would have been paid by then for paid-up future benefits after seven level annual premiums. It is not a comparison only at year-end or only against actual premiums scheduled by the contract.","S002, §7702A(b)."],["R036-P1-C037","Seven-pay premiums are determined at issue using §7702(b)(2) and (e), excluding the burial-increase rule in §7702(e)(2)(C). The first-contract-year death benefit is deemed to continue through maturity, disregarding scheduled reductions after the first seven years.","S002, §7702A(c)(1). Applicable historical interest assumptions still require the issue-date analysis."],["R036-P1-C038","A benefit reduction within the first seven contract years requires testing as though originally issued at the reduced level. A reduction attributable to nonpayment of premiums is disregarded for this rule if benefits are reinstated within 90 days after reduction.","S002, §7702A(c)(2)(A)–(B). No reinstatement or deadline is established for an actual contract."],["R036-P1-C039","An unreflected material change in benefits or other terms makes the contract a new contract, for §7702A, on the day the change takes effect. Seven-pay testing must make appropriate adjustments for cash surrender value under the contract.","S002, §7702A(c)(3)(A)(i)–(ii)."],["R036-P1-C040","Material changes include death-benefit increases and increases/additions of qualified additional benefits. The definition excludes increases attributable to premiums necessary to fund the lowest death-benefit/additional-benefit level payable in the first seven years, after the specified §7702(e)(2)(A)–(B) increases, and interest, earnings, or policyholder dividends on those necessary premiums.","S002, §7702A(c)(3)(B)(i)."],["R036-P1-C041","A cost-of-living increase is excluded from material-change treatment only to the extent provided in regulations, using an established broad-based index and ratable funding over the remaining required-premium period. The statutory regulatory authorization alone does not establish a particular increase qualifies.","S002, §7702A(c)(3)(B)(ii). No applicable regulatory allowance was assumed."],["R036-P1-C042","If initial death benefit is at most $10,000 and at least seven nondecreasing annual premium payments are required, each statutory seven-pay level premium is increased by $75. For this test, the contract and all contracts previously issued by the same company to the same policyholder are one contract.","S002, §7702A(c)(4). This aggregation is not limited to one calendar year."],["R036-P1-C043","Expenses attributable solely to collection of premiums more frequently than annually can enter seven-pay computation only under rules prescribed by regulation. The statute does not itself provide an unrestricted expense adjustment.","S002, §7702A(c)(5)."],["R036-P1-C044","For the specified second-death or simultaneous-death contract, reduction below the lowest death benefit provided during the first seven contract years requires testing as originally issued at the reduced benefit. The reduction clause itself is not limited to reductions occurring during those seven years. This amendment applies to contracts entered into on or after September 14, 1989.","S002, §7702A(c)(6); P.L. 101-239 §7647(b)."],["R036-P1-C045","Failure affects distributions in the contract year of failure and later contract years, plus anticipatory distributions under the statutory/regulatory rule. A distribution within two years before failure is deemed anticipatory. Consequently a later failure can affect an earlier distribution; the text does not simply tax every outstanding balance upon reclassification.","S002, §7702A(d)(1)–(2), concluding sentence."],["R036-P1-C046","For seven-pay testing, “amount paid” means premiums less §72(e) amounts that are not included in gross income, determined without the loan/pledge deeming rule in §72(e)(4)(A). This differs from both §72 investment and §7702 premiums paid.","S002, §7702A(e)(1)(A)."],["R036-P1-C047","A premium portion returned with interest to comply with the seven-pay test within 60 days after the end of the contract year reduces that year’s premiums, excluding the interest. The returned interest is included in the recipient’s gross income notwithstanding §72(e).","S002, §7702A(e)(1)(B)–(C). No actual correction or timely refund established."],["R036-P1-C048","A contract year is the 12-month period beginning with the first month for which the contract is in effect, and corresponding successive periods. It is not necessarily a calendar year. Other §7702A terms generally take their §7702 meanings.","S002, §7702A(e)(2)–(3)."],["R036-P1-C049","The 1988 MEC amendments generally apply to contracts entered into on or after June 21, 1988. The successive-exchange clarification was made effective as part of the 1988 amendments. The 2002 enactment repealed the intervening “old contract” wording in the cash-value adjustment clause as though that amendment had not occurred.","S002, P.L. 100-647 §5012(e)(1); P.L. 106-554 §318(a)(3); P.L. 107-147 §416(f)."],["R036-P1-C050","For the historical issue-date transition, a death-benefit increase of more than $150,000 over the benefit in effect on October 20, 1988 invokes the material-change rules in determining post-June 20, 1988 status. This particular trigger does not apply if, as of June 21, 1988, at least seven level annual premiums were required and at least seven are actually made.","S002, P.L. 100-647 §5012(e)(2). The exception is not automatically an exception to every other material-change rule."],["R036-P1-C051","A pre-June 21, 1988 contract is treated as later-entered if a death benefit or qualified additional benefit is increased/added on or after that date without a preexisting unilateral right to obtain it without additional insurability evidence; or if it is converted after June 20, 1988 from term to nonterm coverage, regardless of a prior conversion right.","S002, P.L. 100-647 §5012(e)(3)(A)–(B)."],["R036-P1-C052","A narrow historical exchange exception concerned MECs entered into after June 20 and before November 10, 1988, requiring at least seven level annual premiums, exchanged within three months after enactment for seven-pay-compliant life insurance, with an election to recognize gain notwithstanding §1035. It does not establish a presently available general MEC “reset.”","S002, P.L. 100-647 §5012(e)(4). No calendar deadline calculated."]]},{"headers":["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],"index":4,"links":[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"uscode.house.gov"}],"row_links":[[],[],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],["R036-P1-C053","Section 72(e) addresses an amount received under an annuity, endowment, or life-insurance contract that is not received as an annuity, and only when another provision of the subtitle does not apply to that amount. A dividend or similar distribution is treated as nonannuity receipt.","S001, §72(e)(1)(A)–(B). Classification comes before ordering."],["R036-P1-C054","For nonannuity life/endowment amounts within §72(e)(5)(C), absent its MEC/regulatory exceptions and other statutory overrides, §72(e)(2)(B)’s income-first allocation and §72(e)(4)(A)’s loan/pledge deeming do not apply. If the post-annuity-starting-date rule does not apply, inclusion is only to the extent the amount exceeds investment in the contract. Thus a genuine policy borrowing is not made a distribution merely by the switched-off deeming rule.","S001, §72(e)(5)(A), (C); qualifications C016–C020, C055, C068, C074. This is not a finding that an actual advance is a genuine loan. \nuscode.house.gov"],["R036-P1-C055","For a MEC, §72(e)(10) overrides the life/endowment exception, applies §72(e)(2)(B) and (4)(A), and substitutes “any person” for “an individual” in the deeming rule. Taxable income still depends on the applicable allocation and exceptions; MEC status does not make every dollar of every loan taxable.","S001, §72(e)(10)(A); S002, §7702A(d)."],["R036-P1-C056","In the pre-annuity-starting-date income-first framework, the amount is allocated to income up to the excess, if any, of cash value without surrender charge immediately before receipt over investment then. The balance is allocated to investment. The statute’s own §72 measurement must be used; §7702’s separate definition is not silently substituted.","S001, §72(e)(2)(B), (3)(A)–(B). Aggregation under C070 may change the relevant combined measurement."],["R036-P1-C057","Within that framework, direct or indirect receipt of an amount as a loan under the contract, or assignment, pledge, or agreement to assign/pledge a portion of contract value, causes that amount or portion to be treated as received as a nonannuity amount. The assigned/pledged portion is not automatically the face death benefit or the entire unassigned contract.","S001, §72(e)(4)(A)(i)–(ii), with MEC substitution in (e)(10)(A)(ii). A collateral event can matter without delivery of new cash by the insurer."],["R036-P1-C058","The loan/pledge deeming sentence does not itself apply in determining investment in the contract, except that investment increases by the amount actually included in gross income because of that deeming. Thus neither subtracting the entire deemed loan from investment nor adding the entire loan as a premium follows from this rule.","S001, §72(e)(4)(A), final sentence. Actual repayments and later applications of debt require separate characterization; no automatic repayment adjustment is invented."],["R036-P1-C059","A MEC assignment or pledge is excepted from §72(e)(4)(A) when it is solely to cover the burial/prearranged-funeral expenses referenced by §7702(e)(2)(C)(iii), and maximum death benefit is at most $25,000. The exception is for assignment/pledge; it is not an express exception for every loan. It does not import all the separate initial-benefit/increase limits of C012.","S001, §72(e)(10)(B)."],["R036-P1-C060","Section 72(e)(5) also protects the specified pre-August 14, 1982 contract treatment, but investment allocable after August 13, 1982 is treated as from a later contract. Accordingly an annuity comparison cannot simply assume that all old and new investment has identical income-first or loan-deeming treatment.","S001, §72(e)(5)(B); P.L. 97-248 §265(c). No retirement-plan renewal transition is imported."],["R036-P1-C061","Section 72(e)(5)(E) separately covers amounts received on complete surrender, redemption, or maturity, and amounts received in full discharge of the contract obligation in the nature of a refund of consideration. It also switches off §72(e)(2)(A) for those amounts. Section 72(e)(10) overrides (5)(C), not the separate full-surrender text in (5)(E).","S001, §72(e)(5)(A), (E), (10)(A); S013, §1.72-11(c)–(d). “Full discharge” here is not a blanket rule for cancellation of a borrower’s debt."],["R036-P1-C062","Rev. Rul. 2009-13 applies §72(e)(5) to a qualifying life contract’s surrender, treats the excess over investment as ordinary income, and does not reduce surrender investment by cost-of-insurance charges in its stated situation. Its surrender facts include no policy loans or prior distributions, so it does not establish a universal indebted-lapse calculation.","S016, Situation 1 analysis, printed pp. 3–5 / PDF indexes 2–4; holding 1, printed p. 11 / index 10."],["R036-P1-C063","Rev. Rul. 2009-13 must be read with Rev. Rul. 2020-05’s modifications concerning the later statutory adjusted-basis rule. Using the original ruling as wholly unchanged would misstate its status. The separate sale analyses are not a foundation for this component.","S017, printed pp. 4–6 / indexes 3–5, modifying S016; stated effective date transactions on/after August 26, 2009."],["R036-P1-C064","Publication 525’s cash-surrender explanation subtracts unrepaid loans not previously included in income in its simplified cost description. This supports the need to reconcile debt and cash in a surrender computation. It does not authorize simultaneously adding the same debt to gross proceeds and subtracting it again from statutory investment, or reducing §72(e)(6) investment every time a non-MEC loan originates.","S018, “Surrender of policy for cash,” read with S001, §72(e)(4)(A), (5)(E), (6). The anti-double-counting conclusion is an analytical reconciliation, not an additional statutory formula."],["R036-P1-C065","The labels “lapse,” “termination,” “discharge,” and “write-off” do not by themselves identify a receipt or its measure. If an event constitutes a complete surrender or refund, C061 controls its ordering; if a MEC loan/pledge is deemed received, C055–C058 control. Whether a particular event applied value to debt, discharged a contractual obligation, or produced another legally relevant amount remains fact-dependent.","S001, §72(e)(4), (5)(E), (6), (10); S018. Partial: the selected noncase authorities do not establish one exhaustive treatment for every zero-cash lapse, interest capitalization, or debt discharge."],["R036-P1-C066","Cash originally advanced, an outstanding principal balance, accrued interest, newly capitalized interest, a new advance, repayment, and later contract settlement are distinct events or measurements. The read §72 provisions do not justify treating every unchanged balance as a new annual receipt or importing §72(p)’s plan-loan rules for interest, renewal, cure, or repayment.","S001, §72(e)(4)(A), (6), (10); boundary (p)(1), (5). Treatment of a particular capitalization or refinancing remains unresolved without its legal character and pertinent published authority."],["R036-P1-C067","A dividend retained by the insurer as a premium or other consideration is not included under §72(e)(2)(B)(i) to that extent. A cash dividend and a retained-premium dividend therefore require different facts and cannot automatically be treated as either a loan or newly paid outside cash.","S001, §72(e)(1)(B), (4)(B), (6)."],["R036-P1-C068","A charge against annuity cash value or life-insurance cash surrender value for coverage under a qualified long-term-care contract that is part of or a rider on the contract is not included in income under §72(e)(11), notwithstanding the specified ordinary/MEC rules. It reduces investment, but not below zero. The 2006 provision generally applies to contracts issued after December 31, 1996, for taxable years beginning after December 31, 2009.","S001, §72(e)(11); P.L. 109-280 §844(g)(1). No rider qualification assumed."],["R036-P1-C069","Qualified long-term-care status requires the separate §7702B predicates, including qualified services, the specified Medicare coordination, guaranteed renewability, restrictions on cash/borrowing/assignment values, premium-refund treatment, and consumer-protection requirements. Section 7702B(e) separates the rider portion and denies a §213 deduction for the specified value-funded charge. Issuance of a qualified rider, or adding provisions needed to conform another long-term-care rider, is not a modification/material change for §§101(f), 7702, or 7702A under the enactment note.","S011, §7702B(b), (c), (e), (g); P.L. 104-191 §321(f)(4). Incorporated qualification standards and actual eligibility remain unestablished."],["R036-P1-C070","For §72(e) inclusion, all MECs issued by the same company to the same policyholder during a calendar year are one MEC; annuities have a corresponding aggregation rule. The rule excludes §72(e)(5)(D) contracts. Additional anti-abuse rules require regulations; “all related contracts everywhere” is not the text. For annuities, the 1988 subsection-(d) amendments apply to contracts entered into after October 21, 1988.","S001, §72(e)(12)(A)–(B); S002, P.L. 100-647 §5012(e)(5); 1989 calendar-year amendment note."],["R036-P1-C071","An individual’s transfer of an annuity without full and adequate consideration has a separate deemed-receipt rule for cash surrender value exceeding investment, with the §1041(a) exception and a transferee investment increase for the amount included. This is not automatically the rule for a collateral assignment of a life contract.","S001, §72(e)(4)(C)(i)–(iii). Full gift/divorce analysis excluded."],["R036-P1-C072","For a transfer for value whose transferee basis is not determined by reference to the transferor’s basis, §72(g) uses actual consideration plus subsequent transferee premiums/consideration, specified transferee prior receipts, and the transferee’s annuity starting date. “Transferee” includes its beneficiary or estate. A pledge alone does not establish all these transfer-for-value predicates.","S001, §72(g)(1)–(3), concluding sentence."],["R036-P1-C073","Amounts actually received as an annuity are governed by §72(a)–(c), including the investment/expected-return framework and annuity-starting-date definition, rather than automatically by nonannuity withdrawal ordering. Qualifying partial annuitization for ten years or more or one or more lives creates a separate portion, pro rata investment allocation, and separate starting date; the 2010 amendment applies to taxable years beginning after December 31, 2010.","S001, §72(a)–(c), P.L. 111-240 §2113(b); S012, §1.72-2(b). Historical annuity-starting-date rules and actuarial tables are not calculated or certified here."],["R036-P1-C074","A nonannuity amount received on or after the annuity starting date is generally included under §72(e)(2)(A), subject to the applicable statutory exceptions, including the full-refund/surrender rule in C061. The pre-start loan/ordering analysis cannot simply be copied to every post-start event.","S001, §72(e)(2)(A), (5)(A), (5)(E)."],["R036-P1-C075","If a contract provides a full-discharge lump sum with an annuity option, the option is exercised within 60 days after the lump sum first becomes payable, and some or all would otherwise be included under §72(e)(1), §72(h) prevents inclusion merely when that lump sum first becomes payable.","S001, §72(h)(1)–(3). No exercise or deadline determined."],["R036-P1-C076","Interest payments on an amount held under an agreement to pay interest are income notwithstanding other §72 provisions. That recipient interest is distinct from interest charged on a policy borrowing.","S001, §72(j)."],["R036-P1-C077","Qualified-plan/IRA contracts have expressly separate §72(e)(5)(D)/(8) treatment. Section 72(p)(5) treats a loan, assignment, or pledge of a contract purchased under a qualified employer plan as a plan loan. These boundaries prevent importing the independent-policy analysis into a retirement arrangement or importing retirement-plan loan limits into this component.","S001, §72(e)(5)(D), (8), (p)(1), (5). The separate retirement-plan-loan report was not used or regenerated."]]},{"headers":["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],"index":5,"links":[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"uscode.house.gov"},{"href":"https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com","text":"Internal Revenue Service\n+1"}],"row_links":[[],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[],[],[],[],[],[],[],[{"href":"https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com","text":"Internal Revenue Service\n+1"}]],"rows":[["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],["R036-P1-C078","If a taxpayer receives an amount under a MEC, §72(v)(1) increases tax for the receipt year by 10% of the portion included in gross income, subject to its exceptions. The base is not automatically gross cash, original borrowing, death benefit, or outstanding principal.","S001, §72(v)(1), read with (e)(4)(A), (10) for deemed receipts. \nuscode.house.gov"],["R036-P1-C079","The age exception applies to a distribution made on or after the date the taxpayer attains 59½. The insured’s age, contract age, or another role’s age does not establish this predicate.","S001, §72(v)(2)(A)."],["R036-P1-C080","The disability exception requires the distribution to be attributable to the taxpayer’s becoming disabled within §72(m)(7): inability to engage in any substantial gainful activity because of a medically determinable physical or mental impairment expected to result in death or to be long-continued and indefinite, with proof in the form and manner required by the Secretary.","S001, §72(v)(2)(B), (m)(7). No disability or medical fact inferred."],["R036-P1-C081","The periodic-payment exception requires a distribution to be part of substantially equal periodic payments, at least annually, for the taxpayer’s life/life expectancy or the joint lives/joint life expectancies of the taxpayer and beneficiary. A single withdrawal, a repayment schedule, or the insurer’s installment label does not establish this exception.","S001, §72(v)(2)(C). No payment method, life-expectancy calculation, or modification conclusion supplied."],["R036-P1-C082","The retrieved §72(v)(2) contains the three exceptions in C079–C081. It does not contain §72(q)’s separate death, immediate-annuity, pre-1982-investment, or other listed exceptions. Nor does a reporting code establish a new statutory exception. This does not imply that a death payment is necessarily taxable; §101 must first be addressed.","S001, §72(v)(2), compared with (q)(2); S006, §101(a)."],["R036-P1-C083","For an annuity, §72(q) has its own 10%-of-includible-amount rule and exceptions: taxpayer age 59½; holder’s death or specified primary-annuitant death; disability; qualifying periodic payments; specified qualified arrangements; pre-August 14, 1982 investment; a qualifying funding asset; amounts governed by §72(t); an immediate annuity; and the specified employer-purchased contract following plan termination. These are annuity boundaries, not MEC exceptions.","S001, §72(q)(1)–(2)(A)–(J), (s)(6)(B), (u)(4). An immediate annuity requires a single premium/consideration, starting within one year, and substantially equal payments at least annually."],["R036-P1-C084","Section 72(q)(3) expressly addresses subsequent modification of qualifying periodic payments, other than death/disability, before age 59½ or within the specified five-year period after payments begin, with recapture and deferral interest. Its §1035-exchange exception requires combined distributions to continue satisfying the periodic-payment requirement. The relevant exchange amendment applies to exchanges after December 31, 2023, with an express no-inference rule for earlier law.","S001, §72(q)(3)(A)–(B); P.L. 117-328 div. T §323(e). This annuity recapture text is not automatically imported into §72(v)."],["R036-P1-C085","An annuity held by a nonnatural person can fall under §72(u)’s current ordinary-income regime rather than ordinary annuity deferral, subject to the natural-person-agent rule and the express estate-at-death, qualified-arrangement, qualified-funding-asset, employer-termination-contract, and immediate-annuity exceptions. Its enactment applicability concerns contributions after February 28, 1986.","S001, §72(u)(1)–(4); P.L. 99-514 §1135(b). No entity, ownership, or annual-income computation established."],["R036-P1-C086","Unresolved authority issue: the 2026 Form 1099-R code notes refer to modifying substantially equal periodic payments under §72(q), (v), or (t) before five years, even after age 59½. The retrieved §72(v) has no express recapture paragraph corresponding to §72(q)(3). The instruction supports its stated reporting direction; it does not, by itself, establish the substantive §72(v) recapture base, interest, or legal authority.","S019, Table 1, code 1 and code 7 notes; S001, §72(v), compared with (q)(3). No independent published authority resolving this issue was established in this investigation. \nInternal Revenue Service\n+1"]]},{"headers":["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],"index":6,"links":[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com","text":"uscode.house.gov"}],"row_links":[[],[{"href":"https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com","text":"uscode.house.gov"}],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],["R036-P1-C087","Section 264(a)(2) denies deductions for amounts paid/accrued on debt incurred or continued to purchase or carry a single-premium life, endowment, or annuity contract. For this purpose, substantially all premiums within four years of purchase, or a post-March 1, 1954 deposit funding a substantial number of future premiums, can make a contract single-premium. The annuity application of (a)(2) is limited to contracts purchased after March 1, 1954.","S004, §264(a)(2), concluding applicability sentence, (c)(1)–(2). \nuscode.house.gov"],["R036-P1-C088","For contracts purchased after August 6, 1963, §264(a)(3) addresses purchase/carry debt under a plan contemplating systematic direct or indirect borrowing of cash-value increases, from the insurer or otherwise, excluding single-premium contracts already covered by (a)(2).","S004, §264(a)(3), concluding applicability sentence."],["R036-P1-C089","The four §264(d) exceptions apply to (a)(3): no debt financing of any part of four annual premiums due during the specified seven-year period; otherwise-disallowed annual paid/accrued amounts no more than $100; debt arising from an unforeseen substantial income loss or financial-obligation increase; or trade/business debt. A substantial premium increase restarts that seven-year period when the first increased premium is paid.","S004, §264(d)(1)–(4), concluding sentence. These exceptions do not erase (a)(2), (a)(4), or §163."],["R036-P1-C090","Section 264(a)(4) separately denies interest deductions on indebtedness with respect to taxpayer-owned life policies covering any individual, or taxpayer-owned endowment/annuity contracts covering any individual, subject to subsection (e). Its purchase-date boundary is after June 20, 1986. It is not conditioned on MEC status.","S004, §264(a)(4), concluding applicability sentence; P.L. 99-514 §1003(c)."],["R036-P1-C091","The key-person exception removes the (a)(4) bar only to the extent aggregate relevant indebtedness for policies/contracts covering the key individual does not exceed $50,000. This is neither a tax-free loan allowance nor a contractual borrowing ceiling. Other deduction restrictions remain.","S004, §264(e)(1)."],["R036-P1-C092","A key person is an officer or 20-percent owner, with the permitted number capped at the greater of five or the lesser of 5% of officers/employees and twenty. Corporate ownership uses direct stock or voting ownership; other entities use capital/profits interests. Controlled-group aggregation applies to the stated ownership test and $50,000 limit, with allocation as prescribed.","S004, §264(e)(3)–(5). Incorporated §§52 and 414 business-group application remains outside the completed component."],["R036-P1-C093","The key-person/pre-1986 deduction allowance is further capped for months beginning after December 31, 1995 by the monthly corporate-bond benchmark specified in §264(e)(2). For contracts purchased on/before June 20, 1986, fixed-rate contracts use the purchase-month benchmark; variable-rate contracts use the third month before the applicable period. That period is normally successive twelve-month periods, with the statutory shorter-period election, historical 90-day election requirement, and consent-to-revoke condition.","S004, §264(e)(2)(A)–(B). No benchmark lookup, historical election, interest rate, or deduction amount established."],["R036-P1-C094","Section 264(f) has a separate proportional interest-disallowance regime based on average unborrowed policy cash values for specified post-June 8, 1997 contracts relative to the stated asset denominator. Its unborrowed-value measure generally subtracts loans from cash surrender value determined without surrender charges, with an alternative valuation rule if that does not reasonably approximate actual value.","S004, §264(f)(1)–(3), (7). This is a third distinct value measure; no averaging convention or business deduction is computed."],["R036-P1-C095","Section 264(f)’s exceptions and coordination matter: specified single-insured business contracts, the owner-and-spouse allowance, §72(u) annuities, qualifying separate master-contract coverage, natural-person ownership, and insurance-company exclusions. The natural-person exception has a business-beneficiary override, with sole-proprietorship/employee-business exclusions and a benefit cap. Partnerships/S corporations are tested at entity level; controlled-group aggregation and coordination with §§264(a), 265, and 263A apply.","S004, §264(f)(4)–(8), read completely. Full incorporated business-tax analysis remains excluded."],["R036-P1-C096","Premium deduction and interest deduction are separate questions. Section 264(a)(1) denies premiums where the taxpayer is directly or indirectly a beneficiary, subject to the specified annuity exceptions in (b). A premium’s inclusion in §72 investment does not itself create a deduction.","S004, §264(a)(1), (b); S001, §72(e)(6)."],["R036-P1-C097","The 1996 amendments generally apply to interest paid/accrued after October 13, 1995, with a historical transition ending before January 1, 1999 for specified earlier debt. The 1997 amendments generally apply to contracts issued after June 8, 1997, in taxable years ending afterward; material death-benefit increases or other material changes can make a contract new for that transition, and added lives under a master contract have the stated separate treatment.","S004, P.L. 104-191 §501(c); S006, P.L. 105-34 §1084(d). Historical transition qualification requires the original debt dates, specified interest cap, aggregation, insured-count limit, and annual percentages; none is applied to current interest."],["R036-P1-C098","The historical four-year income-spreading provision concerns otherwise-taxable amounts under specified §264(a)(4) contracts on complete surrender/redemption/maturity, or a qualifying full-discharge refund, during 1996, 1997, or 1998. It is not a general current surrender or lapse spreading rule. The associated historical premium-test provision also has its own express lapse predicate and former-subsection references.","S004, P.L. 104-191 §501(d)(1)–(2), as amended. No present relief inferred from the note’s continued display."],["R036-P1-C099","Even if a §264 bar does not apply, §163 remains a separate gate. Section 163(a)’s general interest rule is limited by §163(h)’s prohibition of personal-interest deductions for noncorporate taxpayers and applicable exceptions. An exception to a disallowance is not affirmative proof of deductibility.","S005, §163(a), (h)(1)–(2); S004. Full deduction tracing and all §163 exceptions remain held."],["R036-P1-C100","These tax provisions establish inclusion, exclusion, and deduction conditions. They do not supply a contractual right to borrow, an insurer’s repayment terms, protection against lapse, or a suitability recommendation. A deduction limitation is not a prohibition on borrowing.","Scope of S001, S003–S005; contractual/insurance-law analysis expressly excluded by the parent holds."]]},{"headers":["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],"index":7,"links":[],"row_links":[[],[],[],[],[],[]],"rows":[["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],["R036-P1-C101","Section 1035 permits specified exchanges: life to life/endowment/annuity/qualified long-term-care; endowment to qualifying endowment with payments beginning no later, annuity, or qualified long-term-care; annuity to annuity or qualified long-term-care; qualified long-term-care to qualified long-term-care. It does not list annuity-to-life as a permitted direction. Section-specific definitions and the foreign-person limitation remain relevant.","S007, §1035(a)–(c). No replacement transaction recommended or assumed."],["R036-P1-C102","The read final regulation requires the same insured for insurance exchanges and the same obligee or obligees for annuity exchanges. An ownership/insured change is not automatically a qualifying exchange merely because another contract is acquired.","S015, §1.1035-1; current statutory categories in S007 control later additions. Original regulatory issuance-date gap remains recorded."],["R036-P1-C103","Money, other property, and liability assumption can prevent complete nonrecognition. Through §1035(d), §1031(b)–(d) supplies gain-recognition, no-loss, basis, and liability-as-money rules. The incorporated §357(d) definition treats recourse and nonrecourse liabilities differently and requires the specified agreement, expected-payment, collateral, and allocation facts.","S007, §1035(d); S008, §1031(b)–(d); S009, §357(d)(1)–(3). No automatic conclusion that every loan balance is taxable “boot.”"],["R036-P1-C104","A qualifying §1035 exchange generally carries the prescribed adjusted investment/basis framework rather than resetting everything to a new cash premium. Separately, §7702A(a)(2) preserves MEC classification through successive exchanges. Income nonrecognition and MEC status are different questions.","S007, §1035(d); S008, §1031(d); S002, §7702A(a)(2)."],["R036-P1-C105","Section 101’s death-payment exclusion is subject to its own exceptions and limits, including transfer-for-value/reportable-sale rules and separate interest treatment. A MEC still satisfies §7702 by definition, so MEC status alone does not establish the death benefit’s tax result. No beneficiary, death, ownership, transfer, or employer facts are supplied.","S006, §101(a), (c), (d), (f); S002, §7702A(a); S003, §7702(g)(2). Full death-benefit, estate, gift, and employment analysis remains held."]]},{"headers":["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],"index":8,"links":[{"href":"https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com","text":"Internal Revenue Service"}],"row_links":[[],[],[],[],[],[],[],[{"href":"https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com","text":"Internal Revenue Service"}],[]],"rows":[["Claim ID","Supported proposition and consequential conditions","Exact authority and scope"],["R036-P1-C106","Section 6047(d) authorizes/requires the specified issuer reporting for contracts from which designated distributions may be made, as prescribed. Its $10 aggregate annual threshold is a reporting provision, not an income exclusion. Section 6047(g) coordinates with information required under §6050Y.","S021, §6047(d)(1)–(2), (g). Actual filer/event status and full reporting rules remain unestablished."],["R036-P1-C107","For §3405 withholding, “commercial annuity” expressly includes a life-insurance or endowment contract issued by a state-licensed insurance company. That withholding definition does not reclassify every life contract as an annuity for §72’s substantive treatment. Designated distributions, exclusions, payor responsibility, and the cash/property withholding limitation require their own predicates.","S022, §3405(d), (e)(1), (6), (8). No withholding election, rate, or obligation determined."],["R036-P1-C108","Amounts withheld under chapter 24 are credited under §31(a); withholding is not itself the final income-tax liability.","S020, §31(a)(1)–(2)."],["R036-P1-C109","The inspected 2026 instructions identify box 1 as gross distribution, 2a as taxable amount, 2b as relevant determination/distribution checkboxes, 4 as federal income tax withheld, 5 as the specified contributions/premiums recovered, and 7a as distribution codes. The 2026 renumbering must not be silently replaced by an older box-number convention.","S019, “What’s New,” and instructions for those boxes. This describes instructions actually read, not a completed form."],["R036-P1-C110","The instructions direct reporting of matured/redeemed insurance and annuity payments, but state that a life-insurance surrender need not be reported on Form 1099-R when it is reasonable to believe none of the payment is includible. This conditional instruction does not establish that an actual surrender occurred or that any actual payer met the belief predicate.","S019, “Life insurance, annuity, and endowment contracts.”"],["R036-P1-C111","A qualifying §1035 exchange can be reportable despite nonrecognition. The instructions separately address loan cancellation or other property and provide the stated within-company exception where the transaction is solely an exchange, no designated distribution occurs, and adequate basis records are maintained.","S019, “Section 1035 exchange.” This reporting exception is not the substantive qualification test."],["R036-P1-C112","In the inspected code table, L is for deemed distributions under §72(p), not every policy loan. Code 6 addresses §1035 exchanges; code 7 includes the stated life/annuity/endowment and failed-§7702 reporting; W addresses qualifying §72(e)(11) long-term-care charges. A code does not prove qualification, income amount, or an additional-tax exception.","S019, Table 1, codes 6, 7, L, W; see unresolved code-note issue C086. \nInternal Revenue Service"],["R036-P1-C113","No actual information return, withholding entry, payer determination, or tax return has been supplied. Therefore this investigation establishes conditional reporting functions only; it does not establish an actual filing duty, taxable box amount, withholding liability, or final tax bill.","Application limits of S019–S022, and the user’s held facts."]]},{"headers":["Question","Qualifying life contract outside MEC treatment","MEC","Annuity or other separately governed contract","Unknown/nonqualifying contract"],"index":9,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[]],"rows":[["Question","Qualifying life contract outside MEC treatment","MEC","Annuity or other separately governed contract","Unknown/nonqualifying contract"],["Classification prerequisite","Applicable version of §7702 or historical framework must be satisfied; MEC status must separately be excluded.","Must meet §7702 and satisfy §7702A’s failure/exchange definition.","Contract and payment classification must be established; qualified arrangements and §72(u) are separate boundaries.","No favorable classification is presumed. A state-law life contract failing §7702 can trigger §7702(g)."],["Ordinary pre-start cash withdrawal","§72(e)(5) generally recovers investment before inclusion, subject to benefit-reduction and other overrides.","§72(e)(2)(B)/(3) generally allocates income first.","Generally the pre-start income-first framework, but old-investment and qualified-arrangement exceptions matter.","No ordering rule selected until legal classification is established."],["Loan under contract","§72(e)(5)(C) generally turns off §72(e)(4)(A) deeming; actual loan character remains necessary.","Direct/indirect loan receipt is deemed nonannuity receipt, with income allocation and the specific investment increase.","§72(e)(4)(A) can apply to an individual within its framework; grandfathered investment and other exceptions matter.","No blanket borrowing exclusion or deemed-distribution rule established."],["Assignment/pledge/agreement","The same §72(e)(5)(C) switch-off generally applies; an outright transfer remains a different inquiry.","Assigned/pledged value can be deemed received; narrow burial/funeral exception may apply.","Loan/pledge deeming and the distinct annuity transfer-without-consideration rule must not be confused.","Actual legal character, amount, and applicable regime remain unknown."],["Complete surrender/refund/maturity","§72(e)(5)(E) governs qualifying complete events, with investment recovery.","The separate full-event rule must still be considered; MEC status alone does not erase (5)(E).","Same full-event provision can apply; regular annuity payments have a different recovery regime.","Event classification and any §7702(g) effects must first be resolved."],["Lapse/termination with debt","No universal result from the label; determine the legal receipt/settlement and reconcile debt, value, investment, and prior treatment.","Same event inquiry, plus prior deemed receipts, basis increases, aggregation, and MEC timing.","Applicable annuity/other regime and actual event required.","No amount, write-off, cancellation-income treatment, or absence of income inferred."],["Additional tax","§72(v) does not apply merely because it is life insurance.","§72(v): 10% of includible amount unless its own exception applies.","§72(q) is separate; qualified arrangements have separately held rules.","No additional-tax provision or exception selected from labels alone."],["Interest deduction","§§264 and 163 apply independently of favorable borrowing treatment.","Same separate deduction inquiry; MEC status is not the sole test.","Relevant §264/§163 provisions and contract-date boundaries remain separate.","No deduction inferred."],["Reporting","Reporting can depend on a later distribution even if an earlier genuine borrowing was not deemed received.","A deemed receipt can matter without equivalent cash delivery.","Tax-free exchanges and other events may still be reportable.","A form or code cannot cure missing substantive classification."]]},{"headers":["Branch","Supported conditional rule and exact claim/source links","Missing evidence, held rather than requested","Adverse inference to avoid","Next permissible public-law inquiry"],"index":10,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Branch","Supported conditional rule and exact claim/source links","Missing evidence, held rather than requested","Adverse inference to avoid","Next permissible public-law inquiry"],["B01 — Contract qualification unknown","Answered rule: §7702 requires applicable-law status plus the selected federal test; failure can invoke §7702(g). C002, C006–C025; S003 §§7702(a)–(g).","Applicable qualification regime, selected test, compliance history, any failure or waiver.","Marketing category establishes federal life-insurance status; failure means MEC.","Read any further published Treasury qualification rule implicated by the identified legal category; no insurer or policy search."],["B02 — Life contract versus annuity","Answered boundary: §72 distinguishes the contract from whether a payment is received as an annuity; qualified arrangements and §72(u) are separate. C053, C073–C077, C083–C085; S001, S012.","Contract classification, payment character, ownership category, annuity starting status.","Every insurer-issued product, or every installment payment, gets life-policy loan treatment.","Examine the relevant portions of final §1.72 regulations and statutory category definitions only."],["B03 — MEC status unknown","Answered rule: §7702A requires §7702 qualification plus seven-pay failure or the exchange rule. C035–C048; S002 §7702A(a)–(e).","Seven-pay determination, amount-paid history, benefit history, prior exchange status.","All permanent policies are MECs, or an unexplained label proves non-MEC status.","Further published generic guidance on the particular seven-pay computational issue; no private ruling/request."],["B04 — Issue/change/exchange date unknown","Answered transitions; partial legacy cross-reference: issue, conversion, change, and exchange dates can select different statutory rules. C007, C028–C034, C044, C049–C052; S002–S003, S006, S014, S024.","Relevant legal dates and character of changes; historical unilateral rights.","A single original issue date preserves every grandfather rule indefinitely.","Read published guidance resolving the relevant transition, including the §7702(i) cross-reference if that category becomes relevant."],["B05 — Investment unknown","Answered rule: premiums/consideration less prior excluded amounts, with particular deemed-receipt and rider adjustments. C005, C058, C068, C072; S001 §72(e)(4), (6), (11), (g).","Premium/consideration history, prior recoveries, taxable deemed receipts, transfer and rider adjustments.","Cash value, death benefit, premium total, or debt balance automatically equals investment.","Published §72 guidance on the particular adjustment; keep investment and adjusted sale basis separate."],["B06 — Loan versus distribution","Answered conditional rule: actual loan character matters; the non-MEC switch-off and MEC switch-on differ. C053–C058; S001 §72(e)(1)–(6), (10).","Legal character of advance, direct/indirect receipt, pre/post-annuity-start status.","Any cash delivery is taxable income, or every item called a loan is excluded.","Published interpretation of the precise generic transaction category under §72(e)."],["B07 — Collateral assignment/pledge","Answered rule: an agreement to assign/pledge a portion can trigger MEC deeming; narrow burial exception is separate. C057, C059, C071–C072; S001 §72(e)(4), (10)(B), (g).","Portion affected, collateral versus ownership transfer, agreement, purpose, maximum benefit.","No cash means no possible receipt; every assignment is a sale; entire face amount is deemed received.","Published final rules or interpretations distinguishing collateral assignment, outright transfer, and the statutory burial exception."],["B08 — Outstanding debt and interest unknown","Partial: distinguish principal, accrued/capitalized interest, new advances, repayment, and later application of value. C058, C065–C066; S001, S018.","Debt composition, prior taxation, capitalization mechanics, later settlement character.","All outstanding debt is newly taxable each year; retirement-plan accrued-interest instructions govern policy loans.","Search only published Treasury/IRS guidance on capitalization, repayment, and repeated deemed receipts under §72(e)."],["B09 — Surrender/lapse/termination unknown","Answered surrender rule; partial exhaustive lapse treatment: complete events invoke §72(e)(5)(E); labels alone do not establish a receipt. C061–C065; S001, S013, S016–S018.","Actual event, proceeds/value application, surviving rights, discharged obligation, prior basis recovery.","Every lapse produces the same tax, or a lender necessarily writes off debt.","Published generic guidance specifically addressing the relevant noncash termination mechanism; no case-record inquiry."],["B10 — Gross proceeds versus cash received","Answered distinction; partial event measure: reconcile gross contract receipt, debt application, charges, withholding, and net cash without double counting. C003–C005, C056, C064, C109; S001, S003, S018–S019.","Gross settlement components and prior taxable/excluded amounts.","Zero cash proves zero income; debt is counted both in gross proceeds and again as a basis reduction.","Published guidance identifying the legally appropriate gross/net convention for the event."],["B11 — Aggregation/related contracts unknown","Answered statutory rules: calendar-year MEC/annuity grouping differs from all-prior-contract small-benefit grouping and same-owner burial grouping. C012, C042, C070; S001–S003.","Same-company, same-policyholder/owner, issue-calendar-year, prior-contract, and excluded-plan predicates.","Every related contract aggregates, or none does; “contract year” means calendar year.","Published anti-abuse regulations or interpretations for the precise aggregation provision."],["B12 — Additional-tax exception unknown","Answered statutory exceptions; partial modification issue: §72(v) taxes the includible portion, with taxpayer-age, disability, or qualifying periodic-payment exceptions. C078–C086; S001, S019.","Taxpayer-role facts, relevant age/event, qualifying payment series; all remain held.","Insured age suffices; hardship or annuity death exceptions automatically transfer to MECs.","Published authority resolving §72(v) periodic-payment methods/modification and the instruction’s five-year reference."],["B13 — Interest deduction separate","Answered restrictions: §§264/163 impose independent gates and narrow exceptions. C087–C099; S004–S005, S006 note.","Purchase/debt dates, purpose, ownership, business/key-person predicates, actual interest/elections.","Nontaxable loan proceeds imply deductible interest; a §264 exception proves a deduction.","Generic published guidance for the specifically implicated §264 or §163 limitation, within the parent’s deduction hold."],["B14 — Reporting versus substantive tax","Answered distinction: reporting fields and withholding classify information, not final liability; code L is §72(p). C086, C106–C113; S019–S022.","Actual reportable event, payer predicates, report/version, withholding facts.","A sample box, code, or withholding amount establishes tax or a filing duty.","Current public instructions and relevant final reporting regulations for the identified event; no filling or filing."],["B15 — Death/beneficiary treatment not established","Answered boundary: §101 is separate, with its own exceptions; MEC status alone does not determine a death benefit. C025, C082, C105; S002–S003, S006.","Death, beneficiary-role, transfer, ownership, and other §101 predicates.","“Death benefits are tax-free” supplies authority for lifetime borrowing.","Only the relevant published §101 provision if this boundary must later be developed; full death-benefit work stays held."],["B16 — Tax rule versus insurance consequence","Answered scope distinction: tax treatment supplies no borrowing right or coverage/suitability conclusion. C100; S001, S003–S005.","Contractual rights, interest terms, repayment, lapse/coverage effects, nonfederal law.","A favorable tax branch makes borrowing safe, available, or advisable.","No further inquiry in this pass; those subjects are expressly held."],["B17 — Benefit reduction unknown","Answered rules: first-seven-year MEC retesting and first-fifteen-year cash-distribution recapture are different; each has its own lookback/exceptions. C015–C020, C038, C044–C045; S002–S003.","Reduction type/date, distribution relationship, reinstatement, joint-life structure.","A non-MEC withdrawal is invariably investment-first; all reductions use one clock.","Published guidance on the identified reduction and the relevant statutory ceiling or retesting rule."],["B18 — Exchange unknown","Answered statutory boundary; partial historic regulation metadata: permitted direction, same-insured/obligee, boot/liability, basis, and MEC carryover are separate. C101–C104; S002, S007–S009, S015.","Exchange character, consideration, debt assumption, qualifying roles, prior status.","A replacement resets MEC status or every debt balance is taxable exchange consideration.","Published §1035 interpretation and original final-rule history pertinent to the precise generic exchange issue."],["B19 — Long-term-care charge/rider unknown","Answered conditional rule: qualifying value-funded charges have special exclusion/investment reduction; qualifying rider changes have a specific material-change exception. C068–C069; S001, S011.","Qualified rider status, charge character, relevant dates, incorporated qualification predicates.","Every rider charge is an ordinary withdrawal; every rider addition creates a new MEC test period.","Published §7702B/§72(e)(11) guidance and applicable incorporated standards, without medical or policy records."],["B20 — Annuity starting date unknown","Answered boundary: nonannuity receipts before and after that date, regular annuity payments, and full-surrender/refund amounts use different provisions. C053, C056–C057, C061, C073–C075; S001, S012–S013.","Payment character, starting date, partial-annuitization allocation, option exercise.","Pre-start income-first or life-contract recovery rules apply unchanged after annuitization.","The precise final §72 regulation and historical effective-date provision governing the relevant payment category."]]},{"headers":["Audit field","Evidence / entry","Authority / version / pinpoint","Assessment / unresolved issue"],"index":11,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Audit field","Evidence / entry","Authority / version / pinpoint","Assessment / unresolved issue"],["Federal contract category","","",""],["Applicable qualification regime","","",""],["Applicable-law qualification predicate","","",""],["Selected §7702 qualification test","","",""],["Qualification continuity or failure","","",""],["Issue-date predicate","","",""],["Historical transition predicate","","",""],["Contract-year convention","","",""],["Material-change predicate","","",""],["Benefit-reduction predicate","","",""],["Reinstatement predicate","","",""],["Exchange predicate and direction","","",""],["Prior MEC or successor-exchange status","","",""],["Seven-pay determination","","",""],["Seven-pay amount-paid adjustments","","",""],["Premium-return predicate","","",""],["Investment-in-contract components","","",""],["Prior excluded distributions","","",""],["Prior taxable deemed receipts","","",""],["Transfer-for-value adjustment","","",""],["Annuity starting-date predicate","","",""],["Cash receipt characterization","","",""],["Loan receipt characterization","","",""],["Assignment / pledge / agreement characterization","","",""],["Assigned or pledged portion measurement","","",""],["Burial/funeral exception predicate","","",""],["Outstanding principal characterization","","",""],["Accrued interest characterization","","",""],["Capitalized interest characterization","","",""],["Repayment characterization","","",""],["Cash-value measurement convention","","",""],["Surrender-value measurement convention","","",""],["Complete-surrender/refund predicate","","",""],["Lapse / termination / discharge characterization","","",""],["Gross contract receipt components","","",""],["Debt application or assumption components","","",""],["Net cash reconciliation","","",""],["Prior-treatment reconciliation","","",""],["Calendar-year aggregation predicate","","",""],["Other statutory aggregation predicate","","",""],["Additional-tax inclusion base","","",""],["Taxpayer-age exception predicate","","",""],["Disability exception predicate","","",""],["Periodic-payment exception predicate","","",""],["Periodic-payment modification authority","","",""],["Separate interest-deduction provision","","",""],["Long-term-care rider/charge predicate","","",""],["Reporting provision and version","","",""],["Reporting versus withholding reconciliation","","",""],["Death-benefit boundary","","",""],["Contractual-consequence boundary","","",""],["Source legal status","","",""],["Source applicability/effective date","","",""],["Source access date","","",""],["Printed page","","",""],["Zero-based PDF index","","",""],["Actual read extent","","",""],["Authority gap","","",""],["Next permissible public-law inquiry","","",""],["Researcher self-check","","",""]]},{"headers":["Requested item / subquestion","Status","Finding and evidence crosswalk","Missing evidence or exact next permissible inquiry"],"index":12,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Requested item / subquestion","Status","Finding and evidence crosswalk","Missing evidence or exact next permissible inquiry"],["1 — Complete material §72 provisions","Answered, selected complete provisions","S001 read bounds; C005, C053–C086; B05–B14, B20.","Actual application unresolved; no claim of whole-§72 reading."],["1 — Actual life-contract definition","Answered","C002–C034; S003, S006, S014, S024; B01–B02.","Qualification facts held; targeted further published qualification guidance only."],["1 — Actual MEC definition and seven-pay computation","Answered statutory framework","C035–C048; S002; B03, B17.","Actual actuarial test and contract facts held."],["1 — Investment and distinct value definitions","Answered","C003–C005, C013, C046, C056, C058, C094; S001–S004.","Actual measurement inputs absent; no interchange of definitions."],["1 — Nested benefit-reduction/material-change rules","Answered","C015–C020, C038–C045, C069; S002–S003, S011.","Actual reduction/change/rider predicates held."],["1 — Issue/exchange/grandfather triggers","Answered with specific partial issue","C007, C028–C034, C044, C049–C052, C060, C070; S001–S003, S006, S014.","§7702(i)’s post-2020 legacy cross-reference remains partial; next inquiry is published Treasury/IRS interpretation."],["1 — Aggregation","Answered statutory rules","C012, C042, C070, C092, C095; B11.","Additional regulatory anti-abuse application not presumed; exact statutory grouping facts held."],["1 — No uniform permanent-policy/loan/balance inference","Answered boundary","C002, C035, C054–C066, comparison table.","No actual classification supplied."],["2 — Non-MEC versus MEC","Answered","C035, C054–C059, C070, C078–C082; S001–S002.","Application unresolved without qualification/MEC evidence."],["2 — Annuity and excluded-contract comparison","Answered to necessary boundary","C026, C060, C071, C073–C077, C083–C085.","Full annuity/retirement analysis excluded; B02, B20 identify permitted next inquiry."],["2 — Unknown/nonqualifying category","Answered conditional rule","C023–C025; S003 §7702(g); B01.","Actual failure and annual/catch-up amounts unresolved."],["2 — Loan and collateral assignment/pledge","Answered statutory trigger","C054–C059, C071–C072; B06–B07.","Character, affected portion, timing, and exceptions unknown."],["2 — Cash distribution ordering and investment recovery","Answered conditional rule","C005, C016–C020, C053–C061, C067–C075.","Receipt/start-date/aggregation inputs absent."],["2 — Complete surrender/refund/maturity","Answered","C061–C064; S001, S013, S016–S018.","Actual amount received and prior investment unknown."],["2 — Lapse/termination/discharge and zero-cash events","Partial public-law coverage; unresolved application","C064–C066; B08–B10.","Need event-specific published authority and absent event mechanics; no case or record query."],["2 — Separate cash, income, liability, policy debt, and later event","Answered analytical distinction","C005, C057–C058, C064–C066, C103, C107–C113.","No actual reconciliation possible."],["3 — MEC additional-tax base/rate","Answered","C078; S001 §72(v)(1).","Includible amount unknown; E0."],["3 — Age/disability/periodic-payment exceptions","Answered statutory predicates","C079–C082; S001 §§72(v)(2), (m)(7); B12.","Actual taxpayer/event evidence held."],["3 — Periodic-payment modification/recapture","Partial","C084, C086; S001 versus S019.","Published §72(v)-specific authority resolving instruction/statute tension not established."],["3 — Necessary interest-deduction provisions","Answered statutory gates; application excluded/held","C087–C099; S004–S006; B13.","Full deduction tracing, business ownership, rates, elections, and calculations held."],["3 — No borrowing prohibition from deduction restriction","Answered boundary","C091, C099–C100.","Contractual rights and insurance consequences excluded."],["3 — No §72(p), consumer-loan, or death-benefit importation","Answered boundary","C065–C066, C077, C082, C105, C112.","Other components and full death/COD regimes excluded."],["4 — Necessary final regulations","Answered selected reading; partial original-history verification","S012–S015; C029, C061, C073, C102.","Original §1.1035-1 issuance/effectiveness and complete old-T.D. histories not verified."],["4 — Published IRS interpretation and modification status","Answered","S016–S018; C062–C064.","No universal loan-lapse conclusion extrapolated from a loan-free ruling situation."],["4 — Public instructions, version, fields, reporting function","Answered selected material body","S019; C086, C109–C112.","Exact issuance day not established; no whole-document/form-pixel claim."],["4 — Reporting/withholding authority","Answered boundary","S020–S022; C106–C108, C113.","Actual obligation and full reporting rules held."],["4 — Primary-source status/access/read bounds","Answered with disclosed gaps","Source register, C001, source-read/failure log.","Compilation dates are not a complete later-law or judicial audit."],["5 — Provision-specific comparison","Answered","Section 3; C002–C113 as linked there.","All actual applications remain unresolved."],["5 — At least twelve substantive branches","Answered: B01–B20","Each branch contains rule, C/S links, missing evidence, adverse inference, next inquiry.","None populated with an identifying entry."],["5 — Wholly blank evidence/audit worksheet","Answered","Section 5.","All entry cells deliberately blank."],["5 — No borrowing/surrender/lapse/replacement recommendation","Answered scope requirement","C100; B16, B18.","Suitability and contractual consequences excluded."],["6 — Optional mathematical illustration","Omitted with reason","E0; Section 6.","Missing trigger, measurement, ordering, aggregation, and convention inputs."],["6 — No actual deadline/value/deduction/tax bill","Answered scope requirement","E0; no application numbers supplied.","Statutory dates and thresholds are stated only as law."],["Parent holds and other A036 components","Excluded with reason","C077, C100, C105, C113; B13, B15–B16.","Retirement, equity, family help, savings/asset sales, other taxes, nonfederal law, insurer practices, and full remedies/reporting remain reserved."],["Independent review / acceptance","Not performed or claimed","Researcher self-check below.","No component, parent, operational, or publication acceptance."]]},{"headers":["Log entry","What occurred","Treatment and remaining limit"],"index":13,"links":[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t26/s72/"}],"row_links":[[],[],[{"href":"https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com","text":"https://uscode.house.gov/us/usc/119-124/t26/s72/"}],[],[],[],[],[],[],[],[]],"rows":[["Log entry","What occurred","Treatment and remaining limit"],["R036-P1-F001 — Legacy OLRC routes","Initial legacy granule-based requests for §§72, 7702A, 7702, and 264 failed.","Recovered the official versioned bodies recorded in S001–S004. Failure was not treated as absence of law."],["R036-P1-F002 — Intermittent versioned-page access","A later direct request to https://uscode.house.gov/us/usc/119-124/t26/s72/ returned inaccessible.","Reopening the previously retrieved official source succeeded; the complete relevant §72(e) body was re-read. The failed request does not negate the successful read."],["R036-P1-F003 — Current-edition redirects","Some current OLRC routes first returned only a redirect page; certain direct version guesses also failed.","The actual “Continue” links were followed to the source bodies, including §§1031, 6047, and 807. Redirect/index text was not used as substantive law."],["R036-P1-F004 — Additional §7702 regulation lead","An attempted §1.7702-1 access did not supply a usable body.","No rule was inferred from that failure, and no proposed or unavailable text was treated as operative. The successfully read age regulation is specifically §1.7702-2."],["R036-P1-F005 — Search results outside scope","Generic searches returned some private determinations, case discussions, and provider-related material among results.","Those materials were not followed or relied on. No identifying-party, policy, account, case-record, or provider investigation was conducted."],["R036-P1-F006 — Truncated retrieval output","Some long statutory outputs were truncated.","Material sections and notes were reopened or read in bounded portions. Whole-read claims are confined to the instruments identified as whole in the source register."],["R036-P1-F007 — PDF modality","S016 and S017 were available as parsed PDF text.","All stated PDF pages were read as text. Printed pages and zero-based indexes are separately recorded. No claim of pixel or unseen scan inspection."],["R036-P1-F008 — Publication metadata limits","Exact issuance/revision days were not established for the 2025 publication and 2026 instructions; original issuance/effectiveness of §1.1035-1 was not verified.","These are explicit metadata gaps. Version headings and current codification were not substituted for original issuance/effectiveness findings."],["R036-P1-F009 — Same instrument in multiple formats","Rulings and T.D. 9287 were encountered in PDF/eCFR/IRB formats.","Formats are grouped under one source ID per instrument. They are not counted as independent corroboration."],["R036-P1-F010 — Targeted unresolved-authority searches","Generic official-source searches did not establish a complete §72(v)-specific recapture authority or one exhaustive rule covering every zero-cash lapse and capitalized-interest configuration.","The gaps remain C065–C066 and C086. A failed or unproductive search is not a finding that no law exists."]]}],"claims":[{"claim_id":"R036-P1-C001","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C001","Supported proposition and consequential conditions":"The retrieved statutory versions and targeted classification check support the version statements in the source register. They do not establish that every later enactment, judicial development, or original regulatory effective-date instrument was audited.","Exact authority and scope":"S001–S024, their stated currency/read bounds; S023, currency page and 2026 Title 26 classification block."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001","R036-P1-S002","R036-P1-S004"]}},{"claim_id":"R036-P1-C002","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C002","Supported proposition and consequential conditions":"Under the generally applicable §7702 definition, a life-insurance contract must be life insurance under applicable law and satisfy either the cash-value-accumulation test or both the guideline-premium requirements and cash-value corridor. A product label does not establish these elements. The church-plan exception is separately addressed in C027.","Exact authority and scope":"S003, §7702(a)(1)–(2), (j). \nuscode.house.gov"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C003","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C003","Supported proposition and consequential conditions":"For §7702, “cash surrender value” means cash value determined without regard to a surrender charge, policy loan, or reasonable termination dividends. Thus this statutory measurement can differ from cash deliverable after charges and debt offsets.","Exact authority and scope":"S003, §7702(f)(2)(A). This is a section-specific definition, not a universal definition for every tax provision or contract."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C004","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C004","Supported proposition and consequential conditions":"For §7702, “net surrender value” takes surrender charges into account but disregards policy loans. It is therefore distinct from both C003’s measure and net cash actually paid.","Exact authority and scope":"S003, §7702(f)(2)(B)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C005","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C005","Supported proposition and consequential conditions":"For §72(e), investment in the contract on a date is aggregate premiums or other consideration paid before that date, reduced by prior amounts received to the extent excludable under the subtitle or prior income-tax laws. The specific adjustments in C058, C068, and C072 must also be considered. “Basis” is not assumed to equal premiums, account value, or loan balance.","Exact authority and scope":"S001, §72(e)(6), (e)(4)(A), (e)(11), (g). \nuscode.house.gov"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C006","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C006","Supported proposition and consequential conditions":"The cash-value-accumulation test requires contract terms preventing cash surrender value at any time from exceeding the net single premium needed then to fund future benefits. Computation uses the greater of the applicable accumulation-test minimum rate or guaranteed issue rates, the specified mortality/additional-benefit charge rules, and the specified current/future-benefit assumptions.","Exact authority and scope":"S003, §7702(b)(1)–(2), incorporating (c)(3)(B)(i)–(ii), (e)(1)(A), (D)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C007","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C007","Supported proposition and consequential conditions":"For contracts issued after December 31, 2020, the accumulation-test minimum is the lesser of 4% and the statutory insurance interest rate at issue; the guideline-premium minimum is that accumulation minimum plus two percentage points. The insurance interest rate is the lesser of the specified valuation and federal-rate measures for the adjustment year, or latest adjustment year. The federal-rate measure averages the prescribed 60 monthly mid-term rates, annually compounded, and rounds to the nearest whole percentage point. The statutory 2% transition begins January 1, 2021 and ends before the first adjustment year after 2021; it is not proof of a universal 2026 rate.","Exact authority and scope":"S003, §7702(b)(3), (c)(3)(E), (f)(11)(A)–(E); P.L. 116-260 div. EE §205(e). No rate series or actuarial calculation performed."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements","qualification_dates_and_age"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C008","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C008","Supported proposition and consequential conditions":"Under the guideline-premium route, cumulative premiums paid cannot exceed the guideline-premium limitation at any time. That limitation is the greater of the guideline single premium or the sum of guideline level premiums to that date.","Exact authority and scope":"S003, §7702(c)(1)–(2)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C009","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C009","Supported proposition and consequential conditions":"The guideline single premium is determined at issue, except for required adjustments, using the statutory mortality, reasonably expected charge, and interest assumptions. An unspecified charge is zero for this computation; industry experience substitutes for insufficient company experience only to the extent provided by regulations. Guideline level premiums run over a period not ending before insured age 95, using the accumulation minimum instead of the higher guideline minimum. Prevailing tables and the statutory three-year table-transition option are separately relevant.","Exact authority and scope":"S003, §7702(c)(3)–(4), (f)(10). Current mortality clause uses the statutory alternatives in (c)(3)(B)(i); no actual table or charge assumption established."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C010","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C010","Supported proposition and consequential conditions":"Under the corridor route, the death benefit must at all times be at least the applicable percentage of cash surrender value. The percentage uses attained age at the beginning of the contract year and decreases ratably for each full year within the statutory bands reproduced immediately below.","Exact authority and scope":"S003, §7702(d)(1)–(2); age rules in S014. These are qualification ratios, not income-tax rates or borrowing limits."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["corridor"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C011","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C011","Supported proposition and consequential conditions":"Except for the corridor calculation, §7702’s general assumptions deem death and qualified additional benefits nonincreasing, maturity between insured ages 95 and 100, death benefits continuing to that deemed maturity, and endowment benefits—including maturity cash surrender value—not exceeding the least death benefit. Specified death-benefit increases may be recognized to preserve the excess over cash surrender value; the cash-value-accumulation alternative requires the stated net-level-reserve test and premium period not ending before age 95.","Exact authority and scope":"S003, §7702(e)(1), (e)(2)(A)–(B)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C012","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C012","Supported proposition and consequential conditions":"A separate burial/funeral qualification rule permits specified increases for cash-value-accumulation testing only if initial death benefit is at most $5,000, maximum death benefit at most $25,000, annual fixed predetermined increase is at most 10% of initial benefit or 8% of preceding-year benefit, and the purchase is for the specified burial/prearranged-funeral expenses. Initial death benefit aggregates all contracts issued to the same owner. This rule is excluded from the MEC seven-pay computational cross-reference.","Exact authority and scope":"S003, §7702(e)(2)(C); S002, §7702A(c)(1)(B). The burial-increase amendment applies to contracts entered into after October 22, 1986, per S003’s note."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements","qualification_dates_and_age"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C013","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C013","Supported proposition and consequential conditions":"§7702 “premiums paid” is its own measure: premiums less specified nontaxable §72(e) amounts, specified excess-premium distributions, and other amounts prescribed by regulations. A premium portion returned with interest to comply with the guideline requirement within 60 days after the contract year reduces premiums for that year, excluding the interest; the returned interest is income.","Exact authority and scope":"S003, §7702(f)(1)(A)–(C). This is not automatically the same measure as §72 investment or §7702A “amount paid.”"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C014","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C014","Supported proposition and consequential conditions":"A premium otherwise exceeding the guideline limit is disregarded for that limit only to the extent necessary to prevent termination through the end of the contract year, and only if the contract has no cash surrender value at the end of the extension period.","Exact authority and scope":"S003, §7702(f)(6). This is not a general excess-premium permission or loan exclusion."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C015","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C015","Supported proposition and consequential conditions":"An unreflected change in benefits or other terms requires proper adjustments in future §7702 determinations. A §7702 adjustment and a §7702A material change are related inquiries governed by different text.","Exact authority and scope":"S003, §7702(f)(7)(A); compare S002, §7702A(c)(3)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C016","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C016","Supported proposition and consequential conditions":"If an unreflected change reduces benefits during the 15-year period beginning on issue, and a cash distribution results, §72 applies without §72(e)(5) up to the applicable recapture ceiling. Thus a qualifying contract outside the MEC rules can have a distribution for which the ordinary §72(e)(5) treatment is displaced.","Exact authority and scope":"S003, §7702(f)(7)(B). The ceiling is not itself a declaration that its entire amount is taxable. \nuscode.house.gov"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C017","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C017","Supported proposition and consequential conditions":"For a cash-value-accumulation contract and a reduction within the first five years, the recapture ceiling is the excess of cash surrender value immediately before reduction over the net single premium immediately afterward.","Exact authority and scope":"S003, §7702(f)(7)(C)(i)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C018","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C018","Supported proposition and consequential conditions":"For a guideline-premium contract and a reduction within the first five years, the ceiling is the greater of: premiums before reduction exceeding the adjusted guideline limit; or cash surrender value before reduction exceeding the post-reduction cash-value corridor.","Exact authority and scope":"S003, §7702(f)(7)(C)(ii)(I)–(II)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C019","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C019","Supported proposition and consequential conditions":"For a reduction after the first five years but within the first fifteen, the ceiling is the excess of pre-reduction cash surrender value over the post-reduction corridor, whether or not the contract otherwise uses that corridor test.","Exact authority and scope":"S003, §7702(f)(7)(D)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C020","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C020","Supported proposition and consequential conditions":"The benefit-reduction rule also addresses anticipatory distributions. A distribution reducing cash surrender value and made within two years before a benefit reduction is statutorily treated as anticipatory; the ceiling provisions require appropriate adjustments.","Exact authority and scope":"S003, §7702(f)(7)(E), including its regulatory direction."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C021","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C021","Supported proposition and consequential conditions":"Qualification failure is not automatically cured. The Secretary may waive failure only if the taxpayer establishes reasonable error and reasonable remedial steps to the Secretary’s satisfaction.","Exact authority and scope":"S003, §7702(f)(8). No waiver, closing agreement, or request is assumed or pursued."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C022","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C022","Supported proposition and consequential conditions":"Variable contracts require additional classification checks. §7702 testing occurs whenever death benefits change and at least once each 12-month period. §817 defines variable contracts and imposes a diversification condition, subject to its exceptions and regulatory rules. A “variable life” label alone does not establish qualification.","Exact authority and scope":"S003, §7702(f)(9); S010, §817(d), (h). Detailed diversification application remains partial because §1.817-5 and actual investments are outside this completed reading."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C023","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C023","Supported proposition and consequential conditions":"A contract that is life insurance under applicable law but fails §7702(a) can produce annual ordinary income under §7702(g). The statutory annual measure is the excess of the increase in net surrender value plus the cost of protection over premiums paid. Protection cost is the lesser of the specified regulatory uniform-premium measure, using five-year age brackets, or stated mortality charge.","Exact authority and scope":"S003, §7702(g)(1)(A), (B), (D). No annual amount established."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C024","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C024","Supported proposition and consequential conditions":"If such a contract ceases to qualify during a year, income on the contract for all prior taxable years is treated as received or accrued in the cessation year under the statutory catch-up rule.","Exact authority and scope":"S003, §7702(g)(1)(C). This is a qualification-failure rule, not a universal lapse or loan-balance rule."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C025","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C025","Supported proposition and consequential conditions":"For a state-law life contract failing §7702(a), only death proceeds exceeding net surrender value receive the specified deemed-life-insurance treatment under §7702(g)(2). The contract nevertheless remains an insurance contract for the Code under (g)(3). Failure does not automatically make it a MEC or an ordinary annuity.","Exact authority and scope":"S003, §7702(g)(2)–(3). Full beneficiary treatment remains unestablished."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C026","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C026","Supported proposition and consequential conditions":"Section 7702 extends its qualification/failure rules to applicable-law endowment contracts and separately defines qualifying endowment contracts for the Code. Section 72 also includes certain face-amount certificates issued after December 31, 1954 within its endowment-contract terminology. These provisions prevent classification solely from a product title.","Exact authority and scope":"S003, §7702(h); S001, §72(l). The incorporated securities-law certificate definition was not needed to classify an actual instrument and was not independently developed."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C027","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C027","Supported proposition and consequential conditions":"The applicable-law limb of §7702(a) is waived for the specified church-provided death-benefit arrangements for employees and beneficiaries, directly or through the specified organizations. The other federal qualification requirements are not thereby universally waived.","Exact authority and scope":"S003, §7702(j)(1)–(3). No employment, church, or organizational facts supplied; application excluded."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C028","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C028","Supported proposition and consequential conditions":"The printed §7702(i) qualified-20-pay rule requires at least 20 nondecreasing annual premiums and an existing plan filed before September 28, 1983, on file in the appropriate state. Its text substitutes 3% for 4% in §7702(b)(2). Because the 2020 amendment changed that subsection’s rate wording, a modern application of this legacy cross-reference is not resolved here.","Exact authority and scope":"S003, §7702(i); P.L. 98-369 §221(d)(3); 2020 amendment notes. Annual rather than monthly excess-interest crediting does not itself defeat the specified pre-1983-plan predicate."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_and_measurements"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C029","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C029","Supported proposition and consequential conditions":"Final §1.7702-2 governs attained age for specified §7702 tests: actual birthday age or a consistently used contract age within 12 months of actual age, changing annually. First-to-die contracts use the oldest insured; last-to-die contracts generally use the youngest, with the prescribed youngest-surviving rule when both cash-value and future-mortality terms change at death. It applies to contracts issued after December 31, 2008, or on/after October 1, 2007 using the specified 2001 tables; earlier use is permitted only under its consistency condition.","Exact authority and scope":"S014, §1.7702-2(a)–(f). This actuarial insured-age rule does not establish the taxpayer-age exception under §72(v)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_dates_and_age"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C030","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C030","Supported proposition and consequential conditions":"Section 7702 generally applies to contracts issued after December 31, 1984, in taxable years ending afterward. It also reaches specified increasing-death-benefit contracts issued after June 30, 1984 with funding faster than ten-year level premiums, subject to C031–C032. For a master contract, the relevant issue date for an insured is first coverage.","Exact authority and scope":"S003, P.L. 98-369 §221(d)(1), (2)(A), (5)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_dates_and_age"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C031","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C031","Supported proposition and consequential conditions":"The early-1984 application has three alternative exceptions: a contract meeting the specified §101(f) test; a nonflexible-premium contract meeting the modified §7702 test using 3% and the specified latest-maturity/20-year/age-95 assumption; or the specified periodically adjusted level-premium arrangement using at least 3%, with a comparable death-benefit adjustment allowed at the insured’s option.","Exact authority and scope":"S003, P.L. 98-369 §221(d)(2)(B)(i)–(iii). These are historical predicates, not a blanket pre-1985 exemption."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_dates_and_age"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C032","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C032","Supported proposition and consequential conditions":"A further 1984 transition substitutes September 30, 1984 for June 30 when the contract meets the specified modified §7702 test, disregards the specified mortality charges and initial excess-interest guarantees in determining guaranteed rates, and never exceeds the prescribed net-single-premium value. That value uses 3%, the specified 1958 tables, and a level death benefit. A flexible-premium contract issued during 1984 that meets §7702 is treated as meeting §101(f).","Exact authority and scope":"S003, P.L. 98-369 §221(d)(2)(C); §221(b)(3), as added in 1986."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C033","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C033","Supported proposition and consequential conditions":"Section 101(f)’s pre-1985 flexible-premium category has its own predicates. It concerns premiums not fixed as to both timing and amount, excluding a state-law annuity portion other than a settlement option. Its death-payment condition requires either the guideline-limit/corridor route or the cash-value/net-single-premium route. Its corridor begins at 140% through age 40, decreases one percentage point per later year, and bottoms at 105%. Its guideline assumptions use guaranteed charges and the greater of 6% or guaranteed rates, with 4% for level premiums; its net-single-premium interest floor is 4%, or 3% for issuance before July 1, 1983. It has distinct maturity, benefit-change, qualified-additional-benefit, premium-refund-within-60-days, necessary-premium, and reasonable-error provisions. These historical tests cannot be replaced by a current product label.","Exact authority and scope":"S006, §101(f)(1)–(3), read completely. Cash value disregards surrender charges and policy loans; net-single-premium mortality uses the specified guaranteed/all-state-table predicate; maturity and endowment assumptions are those in (2)(D), (3)(G). No actual death exclusion or actuarial determination made."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C034","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C034","Supported proposition and consequential conditions":"The 2017 mortality/table amendments have an effective-date rule for taxable years beginning after December 31, 2017. The accompanying reserve transition and eight-year reserve adjustment concern the specified reserve provisions; they are not a policyholder loan-income spreading rule.","Exact authority and scope":"S003, amendment/effectiveness notes; S024, P.L. 115-97 §13517(c)(1)–(3)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["qualification_dates_and_age"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C035","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C035","Supported proposition and consequential conditions":"A modified endowment contract—MEC—must first meet §7702. It is a contract entered into on or after June 21, 1988 that fails the seven-pay test, or a qualifying contract received in exchange for such a MEC or a successor exchange contract. Failure of §7702 is not the MEC definition.","Exact authority and scope":"S002, §7702A(a)(1)–(2). \nuscode.house.gov"},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C036","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C036","Supported proposition and consequential conditions":"The seven-pay test fails if, at any time during the first seven contract years, accumulated amount paid exceeds the cumulative net level premiums that would have been paid by then for paid-up future benefits after seven level annual premiums. It is not a comparison only at year-end or only against actual premiums scheduled by the contract.","Exact authority and scope":"S002, §7702A(b)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C037","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C037","Supported proposition and consequential conditions":"Seven-pay premiums are determined at issue using §7702(b)(2) and (e), excluding the burial-increase rule in §7702(e)(2)(C). The first-contract-year death benefit is deemed to continue through maturity, disregarding scheduled reductions after the first seven years.","Exact authority and scope":"S002, §7702A(c)(1). Applicable historical interest assumptions still require the issue-date analysis."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C038","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C038","Supported proposition and consequential conditions":"A benefit reduction within the first seven contract years requires testing as though originally issued at the reduced level. A reduction attributable to nonpayment of premiums is disregarded for this rule if benefits are reinstated within 90 days after reduction.","Exact authority and scope":"S002, §7702A(c)(2)(A)–(B). No reinstatement or deadline is established for an actual contract."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C039","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C039","Supported proposition and consequential conditions":"An unreflected material change in benefits or other terms makes the contract a new contract, for §7702A, on the day the change takes effect. Seven-pay testing must make appropriate adjustments for cash surrender value under the contract.","Exact authority and scope":"S002, §7702A(c)(3)(A)(i)–(ii)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C040","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C040","Supported proposition and consequential conditions":"Material changes include death-benefit increases and increases/additions of qualified additional benefits. The definition excludes increases attributable to premiums necessary to fund the lowest death-benefit/additional-benefit level payable in the first seven years, after the specified §7702(e)(2)(A)–(B) increases, and interest, earnings, or policyholder dividends on those necessary premiums.","Exact authority and scope":"S002, §7702A(c)(3)(B)(i)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C041","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C041","Supported proposition and consequential conditions":"A cost-of-living increase is excluded from material-change treatment only to the extent provided in regulations, using an established broad-based index and ratable funding over the remaining required-premium period. The statutory regulatory authorization alone does not establish a particular increase qualifies.","Exact authority and scope":"S002, §7702A(c)(3)(B)(ii). No applicable regulatory allowance was assumed."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C042","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C042","Supported proposition and consequential conditions":"If initial death benefit is at most $10,000 and at least seven nondecreasing annual premium payments are required, each statutory seven-pay level premium is increased by $75. For this test, the contract and all contracts previously issued by the same company to the same policyholder are one contract.","Exact authority and scope":"S002, §7702A(c)(4). This aggregation is not limited to one calendar year."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C043","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C043","Supported proposition and consequential conditions":"Expenses attributable solely to collection of premiums more frequently than annually can enter seven-pay computation only under rules prescribed by regulation. The statute does not itself provide an unrestricted expense adjustment.","Exact authority and scope":"S002, §7702A(c)(5)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C044","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C044","Supported proposition and consequential conditions":"For the specified second-death or simultaneous-death contract, reduction below the lowest death benefit provided during the first seven contract years requires testing as originally issued at the reduced benefit. The reduction clause itself is not limited to reductions occurring during those seven years. This amendment applies to contracts entered into on or after September 14, 1989.","Exact authority and scope":"S002, §7702A(c)(6); P.L. 101-239 §7647(b)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C045","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C045","Supported proposition and consequential conditions":"Failure affects distributions in the contract year of failure and later contract years, plus anticipatory distributions under the statutory/regulatory rule. A distribution within two years before failure is deemed anticipatory. Consequently a later failure can affect an earlier distribution; the text does not simply tax every outstanding balance upon reclassification.","Exact authority and scope":"S002, §7702A(d)(1)–(2), concluding sentence."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C046","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C046","Supported proposition and consequential conditions":"For seven-pay testing, “amount paid” means premiums less §72(e) amounts that are not included in gross income, determined without the loan/pledge deeming rule in §72(e)(4)(A). This differs from both §72 investment and §7702 premiums paid.","Exact authority and scope":"S002, §7702A(e)(1)(A)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C047","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C047","Supported proposition and consequential conditions":"A premium portion returned with interest to comply with the seven-pay test within 60 days after the end of the contract year reduces that year’s premiums, excluding the interest. The returned interest is included in the recipient’s gross income notwithstanding §72(e).","Exact authority and scope":"S002, §7702A(e)(1)(B)–(C). No actual correction or timely refund established."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C048","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C048","Supported proposition and consequential conditions":"A contract year is the 12-month period beginning with the first month for which the contract is in effect, and corresponding successive periods. It is not necessarily a calendar year. Other §7702A terms generally take their §7702 meanings.","Exact authority and scope":"S002, §7702A(e)(2)–(3)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C049","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C049","Supported proposition and consequential conditions":"The 1988 MEC amendments generally apply to contracts entered into on or after June 21, 1988. The successive-exchange clarification was made effective as part of the 1988 amendments. The 2002 enactment repealed the intervening “old contract” wording in the cash-value adjustment clause as though that amendment had not occurred.","Exact authority and scope":"S002, P.L. 100-647 §5012(e)(1); P.L. 106-554 §318(a)(3); P.L. 107-147 §416(f)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C050","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C050","Supported proposition and consequential conditions":"For the historical issue-date transition, a death-benefit increase of more than $150,000 over the benefit in effect on October 20, 1988 invokes the material-change rules in determining post-June 20, 1988 status. This particular trigger does not apply if, as of June 21, 1988, at least seven level annual premiums were required and at least seven are actually made.","Exact authority and scope":"S002, P.L. 100-647 §5012(e)(2). The exception is not automatically an exception to every other material-change rule."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C051","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C051","Supported proposition and consequential conditions":"A pre-June 21, 1988 contract is treated as later-entered if a death benefit or qualified additional benefit is increased/added on or after that date without a preexisting unilateral right to obtain it without additional insurability evidence; or if it is converted after June 20, 1988 from term to nonterm coverage, regardless of a prior conversion right.","Exact authority and scope":"S002, P.L. 100-647 §5012(e)(3)(A)–(B)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C052","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C052","Supported proposition and consequential conditions":"A narrow historical exchange exception concerned MECs entered into after June 20 and before November 10, 1988, requiring at least seven level annual premiums, exchanged within three months after enactment for seven-pay-compliant life insurance, with an election to recognize gain notwithstanding §1035. It does not establish a presently available general MEC “reset.”","Exact authority and scope":"S002, P.L. 100-647 §5012(e)(4). No calendar deadline calculated."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C053","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C053","Supported proposition and consequential conditions":"Section 72(e) addresses an amount received under an annuity, endowment, or life-insurance contract that is not received as an annuity, and only when another provision of the subtitle does not apply to that amount. A dividend or similar distribution is treated as nonannuity receipt.","Exact authority and scope":"S001, §72(e)(1)(A)–(B). Classification comes before ordering."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C054","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C054","Supported proposition and consequential conditions":"For nonannuity life/endowment amounts within §72(e)(5)(C), absent its MEC/regulatory exceptions and other statutory overrides, §72(e)(2)(B)’s income-first allocation and §72(e)(4)(A)’s loan/pledge deeming do not apply. If the post-annuity-starting-date rule does not apply, inclusion is only to the extent the amount exceeds investment in the contract. Thus a genuine policy borrowing is not made a distribution merely by the switched-off deeming rule.","Exact authority and scope":"S001, §72(e)(5)(A), (C); qualifications C016–C020, C055, C068, C074. This is not a finding that an actual advance is a genuine loan. \nuscode.house.gov"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C055","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C055","Supported proposition and consequential conditions":"For a MEC, §72(e)(10) overrides the life/endowment exception, applies §72(e)(2)(B) and (4)(A), and substitutes “any person” for “an individual” in the deeming rule. Taxable income still depends on the applicable allocation and exceptions; MEC status does not make every dollar of every loan taxable.","Exact authority and scope":"S001, §72(e)(10)(A); S002, §7702A(d)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001","R036-P1-S002"]}},{"claim_id":"R036-P1-C056","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C056","Supported proposition and consequential conditions":"In the pre-annuity-starting-date income-first framework, the amount is allocated to income up to the excess, if any, of cash value without surrender charge immediately before receipt over investment then. The balance is allocated to investment. The statute’s own §72 measurement must be used; §7702’s separate definition is not silently substituted.","Exact authority and scope":"S001, §72(e)(2)(B), (3)(A)–(B). Aggregation under C070 may change the relevant combined measurement."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C057","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C057","Supported proposition and consequential conditions":"Within that framework, direct or indirect receipt of an amount as a loan under the contract, or assignment, pledge, or agreement to assign/pledge a portion of contract value, causes that amount or portion to be treated as received as a nonannuity amount. The assigned/pledged portion is not automatically the face death benefit or the entire unassigned contract.","Exact authority and scope":"S001, §72(e)(4)(A)(i)–(ii), with MEC substitution in (e)(10)(A)(ii). A collateral event can matter without delivery of new cash by the insurer."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C058","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C058","Supported proposition and consequential conditions":"The loan/pledge deeming sentence does not itself apply in determining investment in the contract, except that investment increases by the amount actually included in gross income because of that deeming. Thus neither subtracting the entire deemed loan from investment nor adding the entire loan as a premium follows from this rule.","Exact authority and scope":"S001, §72(e)(4)(A), final sentence. Actual repayments and later applications of debt require separate characterization; no automatic repayment adjustment is invented."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C059","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C059","Supported proposition and consequential conditions":"A MEC assignment or pledge is excepted from §72(e)(4)(A) when it is solely to cover the burial/prearranged-funeral expenses referenced by §7702(e)(2)(C)(iii), and maximum death benefit is at most $25,000. The exception is for assignment/pledge; it is not an express exception for every loan. It does not import all the separate initial-benefit/increase limits of C012.","Exact authority and scope":"S001, §72(e)(10)(B)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C060","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C060","Supported proposition and consequential conditions":"Section 72(e)(5) also protects the specified pre-August 14, 1982 contract treatment, but investment allocable after August 13, 1982 is treated as from a later contract. Accordingly an annuity comparison cannot simply assume that all old and new investment has identical income-first or loan-deeming treatment.","Exact authority and scope":"S001, §72(e)(5)(B); P.L. 97-248 §265(c). No retirement-plan renewal transition is imported."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C061","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C061","Supported proposition and consequential conditions":"Section 72(e)(5)(E) separately covers amounts received on complete surrender, redemption, or maturity, and amounts received in full discharge of the contract obligation in the nature of a refund of consideration. It also switches off §72(e)(2)(A) for those amounts. Section 72(e)(10) overrides (5)(C), not the separate full-surrender text in (5)(E).","Exact authority and scope":"S001, §72(e)(5)(A), (E), (10)(A); S013, §1.72-11(c)–(d). “Full discharge” here is not a blanket rule for cancellation of a borrower’s debt."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C062","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C062","Supported proposition and consequential conditions":"Rev. Rul. 2009-13 applies §72(e)(5) to a qualifying life contract’s surrender, treats the excess over investment as ordinary income, and does not reduce surrender investment by cost-of-insurance charges in its stated situation. Its surrender facts include no policy loans or prior distributions, so it does not establish a universal indebted-lapse calculation.","Exact authority and scope":"S016, Situation 1 analysis, printed pp. 3–5 / PDF indexes 2–4; holding 1, printed p. 11 / index 10."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C063","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C063","Supported proposition and consequential conditions":"Rev. Rul. 2009-13 must be read with Rev. Rul. 2020-05’s modifications concerning the later statutory adjusted-basis rule. Using the original ruling as wholly unchanged would misstate its status. The separate sale analyses are not a foundation for this component.","Exact authority and scope":"S017, printed pp. 4–6 / indexes 3–5, modifying S016; stated effective date transactions on/after August 26, 2009."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C064","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C064","Supported proposition and consequential conditions":"Publication 525’s cash-surrender explanation subtracts unrepaid loans not previously included in income in its simplified cost description. This supports the need to reconcile debt and cash in a surrender computation. It does not authorize simultaneously adding the same debt to gross proceeds and subtracting it again from statutory investment, or reducing §72(e)(6) investment every time a non-MEC loan originates.","Exact authority and scope":"S018, “Surrender of policy for cash,” read with S001, §72(e)(4)(A), (5)(E), (6). The anti-double-counting conclusion is an analytical reconciliation, not an additional statutory formula."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C065","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C065","Supported proposition and consequential conditions":"The labels “lapse,” “termination,” “discharge,” and “write-off” do not by themselves identify a receipt or its measure. If an event constitutes a complete surrender or refund, C061 controls its ordering; if a MEC loan/pledge is deemed received, C055–C058 control. Whether a particular event applied value to debt, discharged a contractual obligation, or produced another legally relevant amount remains fact-dependent.","Exact authority and scope":"S001, §72(e)(4), (5)(E), (6), (10); S018. Partial: the selected noncase authorities do not establish one exhaustive treatment for every zero-cash lapse, interest capitalization, or debt discharge."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["surrender_and_modification"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C066","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C066","Supported proposition and consequential conditions":"Cash originally advanced, an outstanding principal balance, accrued interest, newly capitalized interest, a new advance, repayment, and later contract settlement are distinct events or measurements. The read §72 provisions do not justify treating every unchanged balance as a new annual receipt or importing §72(p)’s plan-loan rules for interest, renewal, cure, or repayment.","Exact authority and scope":"S001, §72(e)(4)(A), (6), (10); boundary (p)(1), (5). Treatment of a particular capitalization or refinancing remains unresolved without its legal character and pertinent published authority."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C067","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C067","Supported proposition and consequential conditions":"A dividend retained by the insurer as a premium or other consideration is not included under §72(e)(2)(B)(i) to that extent. A cash dividend and a retained-premium dividend therefore require different facts and cannot automatically be treated as either a loan or newly paid outside cash.","Exact authority and scope":"S001, §72(e)(1)(B), (4)(B), (6)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C068","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C068","Supported proposition and consequential conditions":"A charge against annuity cash value or life-insurance cash surrender value for coverage under a qualified long-term-care contract that is part of or a rider on the contract is not included in income under §72(e)(11), notwithstanding the specified ordinary/MEC rules. It reduces investment, but not below zero. The 2006 provision generally applies to contracts issued after December 31, 1996, for taxable years beginning after December 31, 2009.","Exact authority and scope":"S001, §72(e)(11); P.L. 109-280 §844(g)(1). No rider qualification assumed."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C069","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C069","Supported proposition and consequential conditions":"Qualified long-term-care status requires the separate §7702B predicates, including qualified services, the specified Medicare coordination, guaranteed renewability, restrictions on cash/borrowing/assignment values, premium-refund treatment, and consumer-protection requirements. Section 7702B(e) separates the rider portion and denies a §213 deduction for the specified value-funded charge. Issuance of a qualified rider, or adding provisions needed to conform another long-term-care rider, is not a modification/material change for §§101(f), 7702, or 7702A under the enactment note.","Exact authority and scope":"S011, §7702B(b), (c), (e), (g); P.L. 104-191 §321(f)(4). Incorporated qualification standards and actual eligibility remain unestablished."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C070","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C070","Supported proposition and consequential conditions":"For §72(e) inclusion, all MECs issued by the same company to the same policyholder during a calendar year are one MEC; annuities have a corresponding aggregation rule. The rule excludes §72(e)(5)(D) contracts. Additional anti-abuse rules require regulations; “all related contracts everywhere” is not the text. For annuities, the 1988 subsection-(d) amendments apply to contracts entered into after October 21, 1988.","Exact authority and scope":"S001, §72(e)(12)(A)–(B); S002, P.L. 100-647 §5012(e)(5); 1989 calendar-year amendment note."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001","R036-P1-S002"]}},{"claim_id":"R036-P1-C071","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C071","Supported proposition and consequential conditions":"An individual’s transfer of an annuity without full and adequate consideration has a separate deemed-receipt rule for cash surrender value exceeding investment, with the §1041(a) exception and a transferee investment increase for the amount included. This is not automatically the rule for a collateral assignment of a life contract.","Exact authority and scope":"S001, §72(e)(4)(C)(i)–(iii). Full gift/divorce analysis excluded."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C072","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C072","Supported proposition and consequential conditions":"For a transfer for value whose transferee basis is not determined by reference to the transferor’s basis, §72(g) uses actual consideration plus subsequent transferee premiums/consideration, specified transferee prior receipts, and the transferee’s annuity starting date. “Transferee” includes its beneficiary or estate. A pledge alone does not establish all these transfer-for-value predicates.","Exact authority and scope":"S001, §72(g)(1)–(3), concluding sentence."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C073","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C073","Supported proposition and consequential conditions":"Amounts actually received as an annuity are governed by §72(a)–(c), including the investment/expected-return framework and annuity-starting-date definition, rather than automatically by nonannuity withdrawal ordering. Qualifying partial annuitization for ten years or more or one or more lives creates a separate portion, pro rata investment allocation, and separate starting date; the 2010 amendment applies to taxable years beginning after December 31, 2010.","Exact authority and scope":"S001, §72(a)–(c), P.L. 111-240 §2113(b); S012, §1.72-2(b). Historical annuity-starting-date rules and actuarial tables are not calculated or certified here."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C074","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C074","Supported proposition and consequential conditions":"A nonannuity amount received on or after the annuity starting date is generally included under §72(e)(2)(A), subject to the applicable statutory exceptions, including the full-refund/surrender rule in C061. The pre-start loan/ordering analysis cannot simply be copied to every post-start event.","Exact authority and scope":"S001, §72(e)(2)(A), (5)(A), (5)(E)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C075","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C075","Supported proposition and consequential conditions":"If a contract provides a full-discharge lump sum with an annuity option, the option is exercised within 60 days after the lump sum first becomes payable, and some or all would otherwise be included under §72(e)(1), §72(h) prevents inclusion merely when that lump sum first becomes payable.","Exact authority and scope":"S001, §72(h)(1)–(3). No exercise or deadline determined."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C076","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C076","Supported proposition and consequential conditions":"Interest payments on an amount held under an agreement to pay interest are income notwithstanding other §72 provisions. That recipient interest is distinct from interest charged on a policy borrowing.","Exact authority and scope":"S001, §72(j)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C077","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C077","Supported proposition and consequential conditions":"Qualified-plan/IRA contracts have expressly separate §72(e)(5)(D)/(8) treatment. Section 72(p)(5) treats a loan, assignment, or pledge of a contract purchased under a qualified employer plan as a plan loan. These boundaries prevent importing the independent-policy analysis into a retirement arrangement or importing retirement-plan loan limits into this component.","Exact authority and scope":"S001, §72(e)(5)(D), (8), (p)(1), (5). The separate retirement-plan-loan report was not used or regenerated."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C078","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C078","Supported proposition and consequential conditions":"If a taxpayer receives an amount under a MEC, §72(v)(1) increases tax for the receipt year by 10% of the portion included in gross income, subject to its exceptions. The base is not automatically gross cash, original borrowing, death benefit, or outstanding principal.","Exact authority and scope":"S001, §72(v)(1), read with (e)(4)(A), (10) for deemed receipts. \nuscode.house.gov"},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C079","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C079","Supported proposition and consequential conditions":"The age exception applies to a distribution made on or after the date the taxpayer attains 59½. The insured’s age, contract age, or another role’s age does not establish this predicate.","Exact authority and scope":"S001, §72(v)(2)(A)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C080","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C080","Supported proposition and consequential conditions":"The disability exception requires the distribution to be attributable to the taxpayer’s becoming disabled within §72(m)(7): inability to engage in any substantial gainful activity because of a medically determinable physical or mental impairment expected to result in death or to be long-continued and indefinite, with proof in the form and manner required by the Secretary.","Exact authority and scope":"S001, §72(v)(2)(B), (m)(7). No disability or medical fact inferred."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C081","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C081","Supported proposition and consequential conditions":"The periodic-payment exception requires a distribution to be part of substantially equal periodic payments, at least annually, for the taxpayer’s life/life expectancy or the joint lives/joint life expectancies of the taxpayer and beneficiary. A single withdrawal, a repayment schedule, or the insurer’s installment label does not establish this exception.","Exact authority and scope":"S001, §72(v)(2)(C). No payment method, life-expectancy calculation, or modification conclusion supplied."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C082","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C082","Supported proposition and consequential conditions":"The retrieved §72(v)(2) contains the three exceptions in C079–C081. It does not contain §72(q)’s separate death, immediate-annuity, pre-1982-investment, or other listed exceptions. Nor does a reporting code establish a new statutory exception. This does not imply that a death payment is necessarily taxable; §101 must first be addressed.","Exact authority and scope":"S001, §72(v)(2), compared with (q)(2); S006, §101(a)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C083","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C083","Supported proposition and consequential conditions":"For an annuity, §72(q) has its own 10%-of-includible-amount rule and exceptions: taxpayer age 59½; holder’s death or specified primary-annuitant death; disability; qualifying periodic payments; specified qualified arrangements; pre-August 14, 1982 investment; a qualifying funding asset; amounts governed by §72(t); an immediate annuity; and the specified employer-purchased contract following plan termination. These are annuity boundaries, not MEC exceptions.","Exact authority and scope":"S001, §72(q)(1)–(2)(A)–(J), (s)(6)(B), (u)(4). An immediate annuity requires a single premium/consideration, starting within one year, and substantially equal payments at least annually."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C084","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C084","Supported proposition and consequential conditions":"Section 72(q)(3) expressly addresses subsequent modification of qualifying periodic payments, other than death/disability, before age 59½ or within the specified five-year period after payments begin, with recapture and deferral interest. Its §1035-exchange exception requires combined distributions to continue satisfying the periodic-payment requirement. The relevant exchange amendment applies to exchanges after December 31, 2023, with an express no-inference rule for earlier law.","Exact authority and scope":"S001, §72(q)(3)(A)–(B); P.L. 117-328 div. T §323(e). This annuity recapture text is not automatically imported into §72(v)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C085","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C085","Supported proposition and consequential conditions":"An annuity held by a nonnatural person can fall under §72(u)’s current ordinary-income regime rather than ordinary annuity deferral, subject to the natural-person-agent rule and the express estate-at-death, qualified-arrangement, qualified-funding-asset, employer-termination-contract, and immediate-annuity exceptions. Its enactment applicability concerns contributions after February 28, 1986.","Exact authority and scope":"S001, §72(u)(1)–(4); P.L. 99-514 §1135(b). No entity, ownership, or annual-income computation established."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C086","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C086","Supported proposition and consequential conditions":"Unresolved authority issue: the 2026 Form 1099-R code notes refer to modifying substantially equal periodic payments under §72(q), (v), or (t) before five years, even after age 59½. The retrieved §72(v) has no express recapture paragraph corresponding to §72(q)(3). The instruction supports its stated reporting direction; it does not, by itself, establish the substantive §72(v) recapture base, interest, or legal authority.","Exact authority and scope":"S019, Table 1, code 1 and code 7 notes; S001, §72(v), compared with (q)(3). No independent published authority resolving this issue was established in this investigation. \nInternal Revenue Service\n+1"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["reporting_fields_and_codes"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001"]}},{"claim_id":"R036-P1-C087","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C087","Supported proposition and consequential conditions":"Section 264(a)(2) denies deductions for amounts paid/accrued on debt incurred or continued to purchase or carry a single-premium life, endowment, or annuity contract. For this purpose, substantially all premiums within four years of purchase, or a post-March 1, 1954 deposit funding a substantial number of future premiums, can make a contract single-premium. The annuity application of (a)(2) is limited to contracts purchased after March 1, 1954.","Exact authority and scope":"S004, §264(a)(2), concluding applicability sentence, (c)(1)–(2). \nuscode.house.gov"},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C088","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C088","Supported proposition and consequential conditions":"For contracts purchased after August 6, 1963, §264(a)(3) addresses purchase/carry debt under a plan contemplating systematic direct or indirect borrowing of cash-value increases, from the insurer or otherwise, excluding single-premium contracts already covered by (a)(2).","Exact authority and scope":"S004, §264(a)(3), concluding applicability sentence."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C089","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C089","Supported proposition and consequential conditions":"The four §264(d) exceptions apply to (a)(3): no debt financing of any part of four annual premiums due during the specified seven-year period; otherwise-disallowed annual paid/accrued amounts no more than $100; debt arising from an unforeseen substantial income loss or financial-obligation increase; or trade/business debt. A substantial premium increase restarts that seven-year period when the first increased premium is paid.","Exact authority and scope":"S004, §264(d)(1)–(4), concluding sentence. These exceptions do not erase (a)(2), (a)(4), or §163."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C090","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C090","Supported proposition and consequential conditions":"Section 264(a)(4) separately denies interest deductions on indebtedness with respect to taxpayer-owned life policies covering any individual, or taxpayer-owned endowment/annuity contracts covering any individual, subject to subsection (e). Its purchase-date boundary is after June 20, 1986. It is not conditioned on MEC status.","Exact authority and scope":"S004, §264(a)(4), concluding applicability sentence; P.L. 99-514 §1003(c)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C091","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C091","Supported proposition and consequential conditions":"The key-person exception removes the (a)(4) bar only to the extent aggregate relevant indebtedness for policies/contracts covering the key individual does not exceed $50,000. This is neither a tax-free loan allowance nor a contractual borrowing ceiling. Other deduction restrictions remain.","Exact authority and scope":"S004, §264(e)(1)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C092","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C092","Supported proposition and consequential conditions":"A key person is an officer or 20-percent owner, with the permitted number capped at the greater of five or the lesser of 5% of officers/employees and twenty. Corporate ownership uses direct stock or voting ownership; other entities use capital/profits interests. Controlled-group aggregation applies to the stated ownership test and $50,000 limit, with allocation as prescribed.","Exact authority and scope":"S004, §264(e)(3)–(5). Incorporated §§52 and 414 business-group application remains outside the completed component."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C093","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C093","Supported proposition and consequential conditions":"The key-person/pre-1986 deduction allowance is further capped for months beginning after December 31, 1995 by the monthly corporate-bond benchmark specified in §264(e)(2). For contracts purchased on/before June 20, 1986, fixed-rate contracts use the purchase-month benchmark; variable-rate contracts use the third month before the applicable period. That period is normally successive twelve-month periods, with the statutory shorter-period election, historical 90-day election requirement, and consent-to-revoke condition.","Exact authority and scope":"S004, §264(e)(2)(A)–(B). No benchmark lookup, historical election, interest rate, or deduction amount established."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C094","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C094","Supported proposition and consequential conditions":"Section 264(f) has a separate proportional interest-disallowance regime based on average unborrowed policy cash values for specified post-June 8, 1997 contracts relative to the stated asset denominator. Its unborrowed-value measure generally subtracts loans from cash surrender value determined without surrender charges, with an alternative valuation rule if that does not reasonably approximate actual value.","Exact authority and scope":"S004, §264(f)(1)–(3), (7). This is a third distinct value measure; no averaging convention or business deduction is computed."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C095","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C095","Supported proposition and consequential conditions":"Section 264(f)’s exceptions and coordination matter: specified single-insured business contracts, the owner-and-spouse allowance, §72(u) annuities, qualifying separate master-contract coverage, natural-person ownership, and insurance-company exclusions. The natural-person exception has a business-beneficiary override, with sole-proprietorship/employee-business exclusions and a benefit cap. Partnerships/S corporations are tested at entity level; controlled-group aggregation and coordination with §§264(a), 265, and 263A apply.","Exact authority and scope":"S004, §264(f)(4)–(8), read completely. Full incorporated business-tax analysis remains excluded."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C096","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C096","Supported proposition and consequential conditions":"Premium deduction and interest deduction are separate questions. Section 264(a)(1) denies premiums where the taxpayer is directly or indirectly a beneficiary, subject to the specified annuity exceptions in (b). A premium’s inclusion in §72 investment does not itself create a deduction.","Exact authority and scope":"S004, §264(a)(1), (b); S001, §72(e)(6)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004","R036-P1-S001"]}},{"claim_id":"R036-P1-C097","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C097","Supported proposition and consequential conditions":"The 1996 amendments generally apply to interest paid/accrued after October 13, 1995, with a historical transition ending before January 1, 1999 for specified earlier debt. The 1997 amendments generally apply to contracts issued after June 8, 1997, in taxable years ending afterward; material death-benefit increases or other material changes can make a contract new for that transition, and added lives under a master contract have the stated separate treatment.","Exact authority and scope":"S004, P.L. 104-191 §501(c); S006, P.L. 105-34 §1084(d). Historical transition qualification requires the original debt dates, specified interest cap, aggregation, insured-count limit, and annual percentages; none is applied to current interest."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C098","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C098","Supported proposition and consequential conditions":"The historical four-year income-spreading provision concerns otherwise-taxable amounts under specified §264(a)(4) contracts on complete surrender/redemption/maturity, or a qualifying full-discharge refund, during 1996, 1997, or 1998. It is not a general current surrender or lapse spreading rule. The associated historical premium-test provision also has its own express lapse predicate and former-subsection references.","Exact authority and scope":"S004, P.L. 104-191 §501(d)(1)–(2), as amended. No present relief inferred from the note’s continued display."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C099","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C099","Supported proposition and consequential conditions":"Even if a §264 bar does not apply, §163 remains a separate gate. Section 163(a)’s general interest rule is limited by §163(h)’s prohibition of personal-interest deductions for noncorporate taxpayers and applicable exceptions. An exception to a disallowance is not affirmative proof of deductibility.","Exact authority and scope":"S005, §163(a), (h)(1)–(2); S004. Full deduction tracing and all §163 exceptions remain held."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S004"]}},{"claim_id":"R036-P1-C100","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C100","Supported proposition and consequential conditions":"These tax provisions establish inclusion, exclusion, and deduction conditions. They do not supply a contractual right to borrow, an insurer’s repayment terms, protection against lapse, or a suitability recommendation. A deduction limitation is not a prohibition on borrowing.","Exact authority and scope":"Scope of S001, S003–S005; contractual/insurance-law analysis expressly excluded by the parent holds."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S001","R036-P1-S004"]}},{"claim_id":"R036-P1-C101","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C101","Supported proposition and consequential conditions":"Section 1035 permits specified exchanges: life to life/endowment/annuity/qualified long-term-care; endowment to qualifying endowment with payments beginning no later, annuity, or qualified long-term-care; annuity to annuity or qualified long-term-care; qualified long-term-care to qualified long-term-care. It does not list annuity-to-life as a permitted direction. Section-specific definitions and the foreign-person limitation remain relevant.","Exact authority and scope":"S007, §1035(a)–(c). No replacement transaction recommended or assumed."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["exchange_regulation_and_reporting"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C102","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C102","Supported proposition and consequential conditions":"The read final regulation requires the same insured for insurance exchanges and the same obligee or obligees for annuity exchanges. An ownership/insured change is not automatically a qualifying exchange merely because another contract is acquired.","Exact authority and scope":"S015, §1.1035-1; current statutory categories in S007 control later additions. Original regulatory issuance-date gap remains recorded."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["exchange_regulation_and_reporting"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C103","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C103","Supported proposition and consequential conditions":"Money, other property, and liability assumption can prevent complete nonrecognition. Through §1035(d), §1031(b)–(d) supplies gain-recognition, no-loss, basis, and liability-as-money rules. The incorporated §357(d) definition treats recourse and nonrecourse liabilities differently and requires the specified agreement, expected-payment, collateral, and allocation facts.","Exact authority and scope":"S007, §1035(d); S008, §1031(b)–(d); S009, §357(d)(1)–(3). No automatic conclusion that every loan balance is taxable “boot.”"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["exchange_regulation_and_reporting"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C104","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C104","Supported proposition and consequential conditions":"A qualifying §1035 exchange generally carries the prescribed adjusted investment/basis framework rather than resetting everything to a new cash premium. Separately, §7702A(a)(2) preserves MEC classification through successive exchanges. Income nonrecognition and MEC status are different questions.","Exact authority and scope":"S007, §1035(d); S008, §1031(d); S002, §7702A(a)(2)."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["exchange_regulation_and_reporting"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C105","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C105","Supported proposition and consequential conditions":"Section 101’s death-payment exclusion is subject to its own exceptions and limits, including transfer-for-value/reportable-sale rules and separate interest treatment. A MEC still satisfies §7702 by definition, so MEC status alone does not establish the death benefit’s tax result. No beneficiary, death, ownership, transfer, or employer facts are supplied.","Exact authority and scope":"S006, §101(a), (c), (d), (f); S002, §7702A(a); S003, §7702(g)(2). Full death-benefit, estate, gift, and employment analysis remains held."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":["R036-P1-S002"]}},{"claim_id":"R036-P1-C106","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C106","Supported proposition and consequential conditions":"Section 6047(d) authorizes/requires the specified issuer reporting for contracts from which designated distributions may be made, as prescribed. Its $10 aggregate annual threshold is a reporting provision, not an income exclusion. Section 6047(g) coordinates with information required under §6050Y.","Exact authority and scope":"S021, §6047(d)(1)–(2), (g). Actual filer/event status and full reporting rules remain unestablished."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C107","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C107","Supported proposition and consequential conditions":"For §3405 withholding, “commercial annuity” expressly includes a life-insurance or endowment contract issued by a state-licensed insurance company. That withholding definition does not reclassify every life contract as an annuity for §72’s substantive treatment. Designated distributions, exclusions, payor responsibility, and the cash/property withholding limitation require their own predicates.","Exact authority and scope":"S022, §3405(d), (e)(1), (6), (8). No withholding election, rate, or obligation determined."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C108","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C108","Supported proposition and consequential conditions":"Amounts withheld under chapter 24 are credited under §31(a); withholding is not itself the final income-tax liability.","Exact authority and scope":"S020, §31(a)(1)–(2)."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C109","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C109","Supported proposition and consequential conditions":"The inspected 2026 instructions identify box 1 as gross distribution, 2a as taxable amount, 2b as relevant determination/distribution checkboxes, 4 as federal income tax withheld, 5 as the specified contributions/premiums recovered, and 7a as distribution codes. The 2026 renumbering must not be silently replaced by an older box-number convention.","Exact authority and scope":"S019, “What’s New,” and instructions for those boxes. This describes instructions actually read, not a completed form."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["reporting_fields_and_codes"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C110","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C110","Supported proposition and consequential conditions":"The instructions direct reporting of matured/redeemed insurance and annuity payments, but state that a life-insurance surrender need not be reported on Form 1099-R when it is reasonable to believe none of the payment is includible. This conditional instruction does not establish that an actual surrender occurred or that any actual payer met the belief predicate.","Exact authority and scope":"S019, “Life insurance, annuity, and endowment contracts.”"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["exchange_regulation_and_reporting","reporting_fields_and_codes"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C111","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C111","Supported proposition and consequential conditions":"A qualifying §1035 exchange can be reportable despite nonrecognition. The instructions separately address loan cancellation or other property and provide the stated within-company exception where the transaction is solely an exchange, no designated distribution occurs, and adequate basis records are maintained.","Exact authority and scope":"S019, “Section 1035 exchange.” This reporting exception is not the substantive qualification test."},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["exchange_regulation_and_reporting","reporting_fields_and_codes"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C112","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C112","Supported proposition and consequential conditions":"In the inspected code table, L is for deemed distributions under §72(p), not every policy loan. Code 6 addresses §1035 exchanges; code 7 includes the stated life/annuity/endowment and failed-§7702 reporting; W addresses qualifying §72(e)(11) long-term-care charges. A code does not prove qualification, income amount, or an additional-tax exception.","Exact authority and scope":"S019, Table 1, codes 6, 7, L, W; see unresolved code-note issue C086. \nInternal Revenue Service"},"coordinator_verification_status":"reconciled_with_selected_primary_checks_and_retained_subclaim_limits","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":["reporting_fields_and_codes"],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}},{"claim_id":"R036-P1-C113","area_numbers":[36],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"R036-P1-C113","Supported proposition and consequential conditions":"No actual information return, withholding entry, payer determination, or tax return has been supplied. Therefore this investigation establishes conditional reporting functions only; it does not establish an actual filing duty, taxable box amount, withholding liability, or final tax bill.","Exact authority and scope":"Application limits of S019–S022, and the user’s held facts."},"coordinator_verification_status":"reconciled_original_attribution_or_held_branch_not_freshly_verified","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","selected_evidence_groups":[],"all_original_holds_retained":true,"new_material_correction_pending":false,"underlying_statute_72_7702A_264_not_freshly_verified":[]}}],"sources":[{"source_id":"R036-P1-S001","urls":["https://uscode.house.gov/us/usc/119-124/t26/s72/","https://uscode.house.gov/us/usc/119-124/t26/s72/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S001","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §72, Annuities; certain proceeds of endowment and life insurance contracts. https://uscode.house.gov/us/usc/119-124/t26/s72/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-124, October 15, 2026. Statute as amended; applicable historical and transition provisions must be selected separately.","Actual read bounds, precise pinpoints, and limits":"Read complete (a)–(c), (e)(1)–(12), (f), (g), (h), (j), (l), (m)(7), (q), (u), and (v); selected (p)(1), (p)(5), and (s)(6)(B) for boundaries only. Read material amendment/effective-date notes concerning 1982, 1984, 1986, 1988–1989, 1996, 2006, 2010, and the relevant 2022 annuity amendment. Not a whole-§72 or whole-notes read. \nuscode.house.gov\n+2"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Original later direct failure of supplied§72literal protected without retry; no separate retained successful(e)/(v)native body found through coordination. Original relevant statutory assertions stay attributed/unverified freshly. IRSruling/regulation quotations corroborate only their exact passages, not a fresh§72body. No statute edition/host/query variant or Work/Codex generation.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S002","urls":["https://uscode.house.gov/us/usc/119-121/t26/s7702A/","https://uscode.house.gov/us/usc/119-121/t26/s7702A/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S002","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §7702A, Modified endowment contract defined. https://uscode.house.gov/us/usc/119-121/t26/s7702A/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-121, October 9, 2026. Added by P.L. 100-647, §5012(c), November 10, 1988; substantive applicability generally begins with contracts entered into on or after June 21, 1988, subject to the reproduced transitions.","Actual read bounds, precise pinpoints, and limits":"Whole section (a)–(e), source credit, amendments, effective-date notes, and 2002 construction note read. Particularly §§7702A(a), (c)(2)–(6), (d), (e), and P.L. 100-647 §5012(e), as amended. \nuscode.house.gov"},"coordinator_verification_status":"fresh_literal_access_failed_once_original_attribution_retained","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Supplied119-121§7702A URL failed once404. No retry/variant/workaround. Whole original definition/test/transition record retained as researcher-attributed; current MECclassification/sevenpay/aggregation/additionaltax conclusions not newly certified.","fresh_selected_evidence":[],"new_failure_evidence":[{"packet":"[internal evidence reference]","sha256":"dfb67d4ff40c020b8f6ede36a0c8d3fc0f0a6272aad5172caa30634dea9a4933","chunk":0,"URL":"https://uscode.house.gov/us/usc/119-121/t26/s7702A/","packet_character_bounds_half_open":[0,233],"returned_native_ranges":[],"access_failure":true,"search_miss":false,"actual_selected_lines_read":[],"metadata_navigation_or_unselected_only":true,"complete_native_block_retained":true,"parsed_text_not_pixels":true,"unmodified_failure":"Internal Error ()\nciteturn3168view0 [wordlim: 200] Source: open({\"ref_id\":\"https://uscode.house.gov/us/usc/119-121/t26/s7702A/\",\"lineno\":null}); \nFailed to fetch https://uscode.house.gov/us/usc/119-121/t26/s7702A/: (404) Not Found","no_retry_variant_or_workaround_after_failure":true}],"all_original_holds_retained":true}},{"source_id":"R036-P1-S003","urls":["https://uscode.house.gov/us/usc/119-124/t26/s7702/","https://uscode.house.gov/us/usc/119-124/t26/s7702/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S003","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §7702, Life insurance contract defined. https://uscode.house.gov/us/usc/119-124/t26/s7702/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-124, October 15, 2026. Added July 18, 1984. The 2020 interest-assumption amendments apply to contracts issued after December 31, 2020. Other applicability rules are detailed below.","Actual read bounds, precise pinpoints, and limits":"Whole section (a)–(k), source credit, amendments, and displayed notes read. Material pinpoints: (b)–(f) qualification and measurements; (f)(7) benefit-reduction recapture; (g) failure; (i)–(j) special categories; P.L. 98-369 §221(d), P.L. 116-260 div. EE §205(e). \nuscode.house.gov\n+1"},"coordinator_verification_status":"selected_primary_passages_checked_with_holds","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Fresh complete§7702a–k operative body and selected displayed amendment/applicability notes through462. Ten corridor rows, definitions, rate formula, reduction rules, qualification failure and church/legacy boundaries checked. Only selected note passages freshly read; remaining1984transition and807reserve note remain attributed. OLRCthroughPL119124Oct15 is not fullcurrentness or actuarial certificate.","fresh_selected_evidence":[{"packet":"[internal evidence reference]","sha256":"dfb67d4ff40c020b8f6ede36a0c8d3fc0f0a6272aad5172caa30634dea9a4933","chunk":1,"URL":"https://uscode.house.gov/us/usc/119-124/t26/s7702/","packet_character_bounds_half_open":[314,29586],"returned_native_ranges":[[0,417]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[15,380],[385,417]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"1e092776dc22f31efaa1512ae643bfec716c9e463b453b52b287688388c07c14","chunk":0,"URL":"https://uscode.house.gov/us/usc/119-124/t26/s7702/","packet_character_bounds_half_open":[0,2163],"returned_native_ranges":[[431,448]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[431,448]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"c7c9eb5bb21c758620e5e57b4dc781b75f612940307c87ca2fd293dfc2c9443b","chunk":0,"URL":"https://uscode.house.gov/us/usc/119-124/t26/s7702/","packet_character_bounds_half_open":[0,6754],"returned_native_ranges":[[403,462]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[423,462]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true}],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S004","urls":["https://uscode.house.gov/us/usc/119-134/t26/s264/","https://uscode.house.gov/us/usc/119-134/t26/s264/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S004","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §264, Certain amounts paid in connection with insurance contracts. https://uscode.house.gov/us/usc/119-134/t26/s264/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026. Current statutory body includes separate purchase-date rules and historical transition provisions.","Actual read bounds, precise pinpoints, and limits":"Whole section (a)–(f), source credit, amendments, and displayed notes read. §§264(a)(2)–(4), (c)–(f), and P.L. 104-191 §501(c)–(d) are material. Full business-deduction application remains excluded. \nuscode.house.gov"},"coordinator_verification_status":"fresh_literal_access_failed_once_original_attribution_retained","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Supplied119-134§264URL returned not accessible once. All original deduction/exception/ownership/rate/historical-transition claims retained attributed, not newly verified. No alternateedition/host/query retry, no actual interest deduction or business application.","fresh_selected_evidence":[],"new_failure_evidence":[{"packet":"[internal evidence reference]","sha256":"dfb67d4ff40c020b8f6ede36a0c8d3fc0f0a6272aad5172caa30634dea9a4933","chunk":2,"URL":"https://uscode.house.gov/us/usc/119-134/t26/s264/","packet_character_bounds_half_open":[29668,29901],"returned_native_ranges":[],"access_failure":true,"search_miss":false,"actual_selected_lines_read":[],"metadata_navigation_or_unselected_only":true,"complete_native_block_retained":true,"parsed_text_not_pixels":true,"unmodified_failure":"Internal Error ()\nciteturn3168view2 [wordlim: 200] Source: open({\"ref_id\":\"https://uscode.house.gov/us/usc/119-134/t26/s264/\",\"lineno\":null}); \nURL https://uscode.house.gov/us/usc/119-134/t26/s264/ is not accessible via this tool.","no_retry_variant_or_workaround_after_failure":true}],"all_original_holds_retained":true}},{"source_id":"R036-P1-S005","urls":["https://uscode.house.gov/us/usc/119-134/t26/s163/","https://uscode.house.gov/us/usc/119-134/t26/s163/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S005","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §163, Interest. https://uscode.house.gov/us/usc/119-134/t26/s163/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026.","Actual read bounds, precise pinpoints, and limits":"Selected (a), (h)(1), and (h)(2) read for the separate deduction gate. Not a complete §163, investment-interest, business-interest, residence-interest, or other personal-interest-exception analysis. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S006","urls":["https://uscode.house.gov/us/usc/119-134/t26/s101/","https://uscode.house.gov/us/usc/119-134/t26/s101/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S006","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §101, Certain death benefits. https://uscode.house.gov/us/usc/119-134/t26/s101/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026.","Actual read bounds, precise pinpoints, and limits":"Read (a)–(f), with (f)’s concluding clauses separately completed. Used (a), (c), and (d) only as death-benefit boundaries; read (f) completely for pre-1985 flexible-premium predicates. Read P.L. 105-34 §1084(d) note concerning post-June 8, 1997 contracts and material changes. Not a complete death-benefit or employer-owned-insurance analysis. \nuscode.house.gov\n+2"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S007","urls":["https://uscode.house.gov/us/usc/119-134/t26/s1035/","https://uscode.house.gov/us/usc/119-134/t26/s1035/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S007","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §1035, Certain exchanges of insurance policies. https://uscode.house.gov/us/usc/119-134/t26/s1035/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026. Long-term-care exchange amendments apply to exchanges after December 31, 2009.","Actual read bounds, precise pinpoints, and limits":"Whole (a)–(d), source/amendment/effective-date notes read. Foreign-person regulatory limitation identified but not developed. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S008","urls":["https://uscode.house.gov/us/usc/119-134/t26/s1031/","https://uscode.house.gov/us/usc/119-134/t26/s1031/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S008","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §1031, Exchange of real property held for productive use or investment, incorporated provisions. https://uscode.house.gov/us/usc/119-134/t26/s1031/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026.","Actual read bounds, precise pinpoints, and limits":"Read complete (b)–(d) because §1035(d) incorporates them. No real-estate exchange timing rules applied. Not a whole-section/history read. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S009","urls":["https://uscode.house.gov/us/usc/119-134/t26/s357/","https://uscode.house.gov/us/usc/119-134/t26/s357/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S009","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §357, Assumption of liability, incorporated definition. https://uscode.house.gov/us/usc/119-134/t26/s357/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026.","Actual read bounds, precise pinpoints, and limits":"Read complete (d)(1)–(3) for the liability-assumption definition incorporated by §1031(d). Corporate-transfer treatment and complete historical applicability not investigated. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S010","urls":["https://uscode.house.gov/us/usc/119-134/t26/s817/","https://uscode.house.gov/us/usc/119-134/t26/s817/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S010","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §817, Treatment of variable contracts. https://uscode.house.gov/us/usc/119-134/t26/s817/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026.","Actual read bounds, precise pinpoints, and limits":"Read complete (d) and (h) for variable-contract and diversification boundaries. Treas. Reg. §1.817-5 and underlying asset qualification were not comprehensively investigated. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S011","urls":["https://uscode.house.gov/us/usc/119-134/t26/s7702B/","https://uscode.house.gov/us/usc/119-134/t26/s7702B/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S011","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §7702B, Treatment of qualified long-term care insurance. https://uscode.house.gov/us/usc/119-134/t26/s7702B/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026. Includes 1996 enactment and 2006 coordination notes.","Actual read bounds, precise pinpoints, and limits":"Read (b), (c), (e), (g) and material displayed notes, including P.L. 104-191 §321(f)(4). No medical-status determination, state-law qualification investigation, or complete reading of incorporated insurance model standards. \nuscode.house.gov\n+1"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S012","urls":["https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2","https://www.ecfr.gov/current/title-26/section-1.72-2?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S012","Issuer, instrument, and complete literal HTTPS URL":"Treasury; eCFR, Treas. Reg. §1.72-2, Applicability of section 72. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-2","Version, legal status, and effectiveness":"Codified final regulation; retrieved eCFR status through October 22, 2026. Source history includes T.D. 6500, November 26, 1960; T.D. 6497, October 20, 1960; T.D. 6885, June 2, 1966.","Actual read bounds, precise pinpoints, and limits":"Read (a)(1)–(2), (b)(1)–(3) and source note. Used for annuity/nonannuity boundary, subject to later statutes. Original Treasury-decision preambles and all historical effectiveness provisions not read. \necfr.gov\n+1"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S013","urls":["https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11","https://www.ecfr.gov/current/title-26/section-1.72-11?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S013","Issuer, instrument, and complete literal HTTPS URL":"Treasury; eCFR, Treas. Reg. §1.72-11, Amounts not received as annuity payments. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11","Version, legal status, and effectiveness":"Codified final regulation; retrieved status through October 16, 2026. Source history includes T.D. 6500, November 26, 1960; T.D. 6885, June 2, 1966; T.D. 8115, December 19, 1986.","Actual read bounds, precise pinpoints, and limits":"Whole (a)–(h) and source note read. Material surrender provision (d)(1)–(2). Historical caps and obsolete cross-references were not treated as overriding amended §72. Full original-decision effectiveness audit not performed. \necfr.gov\n+2"},"coordinator_verification_status":"selected_primary_passages_checked_with_holds","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Fresh selected complete(d) surrender/redemption/maturity provision only; neither whole1.72-11 nor its operative era/history freshly certified. Oldstatutorycrossreferences/caps and laterannuity distinctions retained; cannot substitute it for current72held body. No PDFpixels.","fresh_selected_evidence":[{"packet":"[internal evidence reference]","sha256":"c7c9eb5bb21c758620e5e57b4dc781b75f612940307c87ca2fd293dfc2c9443b","chunk":3,"URL":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFR807fc2326e73cb3/section-1.72-11","packet_character_bounds_half_open":[18878,30509],"returned_native_ranges":[[111,113],[154,189],[217,217]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[167,172]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true}],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S014","urls":["https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2","https://www.irs.gov/irb/2006-46_IRB","https://www.irs.gov/irb/2006-46_IRB?utm_source=chatgpt.com","https://www.ecfr.gov/current/title-26/section-1.7702-2?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S014","Issuer, instrument, and complete literal HTTPS URL":"Treasury, Treas. Reg. §1.7702-2, Attained age of the insured under a life insurance contract; T.D. 9287. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2. Same instrument in https://www.irs.gov/irb/2006-46_IRB.","Version, legal status, and effectiveness":"Final T.D. 9287, September 13, 2006, 71 FR 53970; effective that day, with distinct contract applicability under paragraph (f). First retrieved eCFR snapshot through October 13, 2026. IRB publication November 13, 2006.","Actual read bounds, precise pinpoints, and limits":"Whole regulation (a)–(f), including examples and applicability, read. Selected T.D. preamble/version material read in IRB, not the whole bulletin. These formats are one instrument, not independent corroboration. \necfr.gov\n+1"},"coordinator_verification_status":"selected_primary_passages_checked_with_holds","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Fresh complete1.7702-2a–f body including six source-native examples read across exact packets; no new example computation. eCFRdisplayOct23lastamendedOct19, not fullamendmentaudit. Source-noteTD9287date visible; IRBpreamble/originaleffectivehistory not freshly reopened.","fresh_selected_evidence":[{"packet":"[internal evidence reference]","sha256":"a7410b78f27168f2f3953b546a6e944dcbd65cb37dad9a394aec0c43d806df97","chunk":2,"URL":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2","packet_character_bounds_half_open":[12887,19652],"returned_native_ranges":[[0,113]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[67,69],[98,113]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"5fb878b371dafbe5cc1067743ba0f2186b87753ac5c94826526cc0415689479d","chunk":2,"URL":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2","packet_character_bounds_half_open":[18706,27883],"returned_native_ranges":[[115,188]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[115,157]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"c7c9eb5bb21c758620e5e57b4dc781b75f612940307c87ca2fd293dfc2c9443b","chunk":1,"URL":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRc1c6d714d9aed32/section-1.7702-2","packet_character_bounds_half_open":[6836,13534],"returned_native_ranges":[[101,131]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[101,115]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true}],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S015","urls":["https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1","https://www.ecfr.gov/current/title-26/section-1.1035-1?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S015","Issuer, instrument, and complete literal HTTPS URL":"Treasury; eCFR, Treas. Reg. §1.1035-1, Certain exchanges of insurance policies. https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1","Version, legal status, and effectiveness":"Codified final regulation; retrieved status through October 23, 2026. Original issuance/effective date not verified in the retrieved section.","Actual read bounds, precise pinpoints, and limits":"Whole section text read. Same-insured/same-obligee and money/other-property provisions used. Its older exchange-category wording was read with current §1035, including later long-term-care amendments. \necfr.gov"},"coordinator_verification_status":"selected_primary_passages_checked_with_holds","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Fresh whole1.1035-1operativebody; sameinsured/sameobligees, money/otherproperty andbasisincorporations checked. Olderexchangecategories held against laterstatutory framework, current1035/1031/357bodies not freshlyverified. Originalissuance/effectivenessgap remains. eCFRdisplayOct26lastamendedOct26notfullhistoryaudit.","fresh_selected_evidence":[{"packet":"[internal evidence reference]","sha256":"c7c9eb5bb21c758620e5e57b4dc781b75f612940307c87ca2fd293dfc2c9443b","chunk":2,"URL":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1","packet_character_bounds_half_open":[13616,18796],"returned_native_ranges":[[0,105]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[67,69],[98,105]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"e212d9246607efed83276208a8d9ba6a1af86d1d9f12c5523dfdb7ef46f45348","chunk":0,"URL":"https://www.ecfr.gov/current/title-26/chapter-I/subchapter-A/part-1/subject-group-ECFRbf83dcc4bd89326/section-1.1035-1","packet_character_bounds_half_open":[0,5808],"returned_native_ranges":[[33,141]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[67,69],[98,110]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true}],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S016","urls":["https://www.irs.gov/pub/irs-drop/rr-09-13.pdf","https://www.irs.gov/irb/2009-21_IRB","https://www.irs.gov/pub/irs-drop/rr-09-13.pdf?utm_source=chatgpt.com","https://www.irs.gov/irb/2009-21_IRB?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S016","Issuer, instrument, and complete literal HTTPS URL":"IRS, Rev. Rul. 2009-13. https://www.irs.gov/pub/irs-drop/rr-09-13.pdf. Published in https://www.irs.gov/irb/2009-21_IRB.","Version, legal status, and effectiveness":"Published IRS interpretation, 2009-21 I.R.B. 1029, May 26, 2009. Modified by S017; not relied on as an unmodified instrument.","Actual read bounds, precise pinpoints, and limits":"All 12 PDF pages read as parsed text, indexes 0–11. Surrender analysis: printed pp. 3–5 / indexes 2–4; holding 1: printed p. 11 / index 10. Its surrender situation has no outstanding loan or prior withdrawals. No PDF-pixel inspection claimed; no case opinions investigated. \nirs.gov\n+1"},"coordinator_verification_status":"selected_primary_passages_checked_with_holds","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Fresh selectedSituation1facts andprintedpp3–5/PDFindices2–4surrenderanalysis only. Originalall12pagesread remainsresearcher-attributed, freshnoall12claim. No policyloan/priorwithdrawal inrulingfacts; ordinaryincome/cost treatmentnotuniversalindebtedlapse. Rulingmodifiedstatusreadseparately, underlyingcitedcasesunreopened.","fresh_selected_evidence":[{"packet":"[internal evidence reference]","sha256":"a7410b78f27168f2f3953b546a6e944dcbd65cb37dad9a394aec0c43d806df97","chunk":0,"URL":"https://www.irs.gov/pub/irs-drop/rr-09-13.pdf","packet_character_bounds_half_open":[0,6311],"returned_native_ranges":[[0,76]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[0,23],[35,76]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"5fb878b371dafbe5cc1067743ba0f2186b87753ac5c94826526cc0415689479d","chunk":0,"URL":"https://www.irs.gov/pub/irs-drop/rr-09-13.pdf","packet_character_bounds_half_open":[0,12271],"returned_native_ranges":[[38,175]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[38,92]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true}],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S017","urls":["https://www.irs.gov/pub/irs-drop/rr-20-05.pdf","https://www.irs.gov/irb/2020-09_IRB","https://www.irs.gov/pub/irs-drop/rr-20-05.pdf?utm_source=chatgpt.com","https://www.irs.gov/irb/2020-09_IRB?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S017","Issuer, instrument, and complete literal HTTPS URL":"IRS, Rev. Rul. 2020-05. https://www.irs.gov/pub/irs-drop/rr-20-05.pdf. Published in https://www.irs.gov/irb/2020-09_IRB.","Version, legal status, and effectiveness":"Published IRS interpretation, 2020-9 I.R.B. 454, February 24, 2020. Its stated effective date is transactions on or after August 26, 2009.","Actual read bounds, precise pinpoints, and limits":"All six PDF pages read as parsed text, indexes 0–5. Material modification discussion printed pp. 4–5 / indexes 3–4; effect on other documents and effective date printed p. 6 / index 5. Used to establish S016’s modified status, not to regenerate an asset-sale component. No pixel inspection. \nirs.gov\n+1"},"coordinator_verification_status":"selected_primary_passages_checked_with_holds","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Fresh selected§1016amendment/modification/effectivedatebody printedpp4–6/indices3–5 andinitialdatecontext. Salesexamplesonlyretained unmodified, not developed as asset-sale component or new calculation. No whole6pagefreshread or judicialhistory/pixel claim.","fresh_selected_evidence":[{"packet":"[internal evidence reference]","sha256":"a7410b78f27168f2f3953b546a6e944dcbd65cb37dad9a394aec0c43d806df97","chunk":1,"URL":"https://www.irs.gov/pub/irs-drop/rr-20-05.pdf","packet_character_bounds_half_open":[6393,12805],"returned_native_ranges":[[0,71]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[0,21],[68,71]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"5fb878b371dafbe5cc1067743ba0f2186b87753ac5c94826526cc0415689479d","chunk":1,"URL":"https://www.irs.gov/pub/irs-drop/rr-20-05.pdf","packet_character_bounds_half_open":[12353,18624],"returned_native_ranges":[[48,50],[54,121]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[68,116]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true}],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S018","urls":["https://www.irs.gov/publications/p525","https://www.irs.gov/publications/p525?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S018","Issuer, instrument, and complete literal HTTPS URL":"IRS, Publication 525 (2025), Taxable and Nontaxable Income. https://www.irs.gov/publications/p525","Version, legal status, and effectiveness":"Public explanatory publication, 2025 version; exact original issuance/revision day not established. It is not a statute or final regulation.","Actual read bounds, precise pinpoints, and limits":"Selected “Life Insurance Proceeds,” especially complete “Surrender of policy for cash” paragraph, read. Not the whole publication. Its simplified treatment of unrepaid loans is qualified below; it does not establish all lapse scenarios. \nInternal Revenue Service"},"coordinator_verification_status":"selected_primary_passages_checked_with_holds","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Fresh complete2025cash-surrender paragraph only. Simplified unrepaid-loan cost wording remains guidance, not a universal debt/netproceeds/basis formula or everylapseevent. Exactissuance/versionhistoryheld, no wholepublication.","fresh_selected_evidence":[{"packet":"[internal evidence reference]","sha256":"1e092776dc22f31efaa1512ae643bfec716c9e463b453b52b287688388c07c14","chunk":1,"URL":"https://www.irs.gov/publications/p525","packet_character_bounds_half_open":[2245,11137],"returned_native_ranges":[[372,394],[1053,1060],[2471,2490],[4229,4288],[4458,4508]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[2474,2477]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true}],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S019","urls":["https://www.irs.gov/instructions/i1099r","https://www.irs.gov/instructions/i1099r?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S019","Issuer, instrument, and complete literal HTTPS URL":"IRS, Instructions for Forms 1099-R and 5498 (2026). https://www.irs.gov/instructions/i1099r","Version, legal status, and effectiveness":"Public reporting instructions, 2026 version; exact issuance/revision day not established. A tax-year heading is not a substantive effective-date finding.","Actual read bounds, precise pinpoints, and limits":"Read material body: life-insurance/annuity/endowment reporting; §1035 exchanges; boxes 1, 2a, 2b, 4, 5, 7a; relevant distribution-code entries and notes. Not whole instructions; no blank-form PDF or pixels inspected; no form completed. The §72(v) periodic-payment coding issue is explicitly unresolved below. \nInternal Revenue Service\n+3"},"coordinator_verification_status":"selected_primary_passages_checked_with_holds","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Fresh selected2026material instructions includinglifecontracts/1035, selectedfields2a/2b/4/5,7aboxrenumbering,codes1/2/6/7/L/Wandfiveyearmodificationnotes. No underlying72vrecaptureauthority/finaltax/actualfilingfinding; fullinstructions,formPDF,pixelsandfullreportingstatutesnotfreshlyverified. Exactrevisiondayheld.","fresh_selected_evidence":[{"packet":"[internal evidence reference]","sha256":"1e092776dc22f31efaa1512ae643bfec716c9e463b453b52b287688388c07c14","chunk":2,"URL":"https://www.irs.gov/instructions/i1099r","packet_character_bounds_half_open":[11219,17779],"returned_native_ranges":[[515,519],[557,557],[1051,1079],[1148,1148],[1156,1159],[1167,1167]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[1148,1148],[1156,1158],[1167,1167]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"1e092776dc22f31efaa1512ae643bfec716c9e463b453b52b287688388c07c14","chunk":3,"URL":"https://www.irs.gov/instructions/i1099r","packet_character_bounds_half_open":[17861,30106],"returned_native_ranges":[[118,172],[427,444],[604,622],[766,774],[823,829],[1163,1164],[1675,1677]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[430,436],[772,772],[1164,1164]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"e212d9246607efed83276208a8d9ba6a1af86d1d9f12c5523dfdb7ef46f45348","chunk":1,"URL":"https://www.irs.gov/instructions/i1099r","packet_character_bounds_half_open":[5890,19008],"returned_native_ranges":[[387,390],[392,460]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[425,438]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"e212d9246607efed83276208a8d9ba6a1af86d1d9f12c5523dfdb7ef46f45348","chunk":2,"URL":"https://www.irs.gov/instructions/i1099r","packet_character_bounds_half_open":[19090,32021],"returned_native_ranges":[[1118,1190]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[1141,1167],[1189,1189]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"b1aaebeb6e03b64a54ca754759cb0711ce17deb73b059288cf14202389dfbb90","chunk":1,"URL":"https://www.irs.gov/instructions/i1099r","packet_character_bounds_half_open":[1197,2398],"returned_native_ranges":[[1208,1211]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[1208,1208]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"b1aaebeb6e03b64a54ca754759cb0711ce17deb73b059288cf14202389dfbb90","chunk":2,"URL":"https://www.irs.gov/instructions/i1099r","packet_character_bounds_half_open":[2480,27479],"returned_native_ranges":[[173,181],[193,201],[569,569],[579,579],[759,777],[809,990],[1028,1028],[1036,1040],[1584,1595],[1602,1602],[1628,1629],[1669,1669],[1685,1698]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[763,763],[772,772],[816,830],[929,937],[987,990],[1028,1028],[1036,1036]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true},{"packet":"[internal evidence reference]","sha256":"b1aaebeb6e03b64a54ca754759cb0711ce17deb73b059288cf14202389dfbb90","chunk":3,"URL":"https://www.irs.gov/instructions/i1099r","packet_character_bounds_half_open":[27561,30331],"returned_native_ranges":[[97,106],[314,342]],"access_failure":false,"search_miss":false,"actual_selected_lines_read":[[319,339]],"metadata_navigation_or_unselected_only":false,"complete_native_block_retained":true,"parsed_text_not_pixels":true}],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S020","urls":["https://uscode.house.gov/us/usc/119-134/t26/s31/","https://uscode.house.gov/us/usc/119-134/t26/s31/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S020","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §31, Tax withheld on wages, incorporated credit rule. https://uscode.house.gov/us/usc/119-134/t26/s31/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026.","Actual read bounds, precise pinpoints, and limits":"Complete (a)(1)–(2) read for crediting chapter 24 withholding. Not a return or tax-payment calculation. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S021","urls":["https://uscode.house.gov/us/usc/119-134/t26/s6047/","https://uscode.house.gov/us/usc/119-134/t26/s6047/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S021","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §6047, Returns relating to certain trusts and annuity plans. https://uscode.house.gov/us/usc/119-134/t26/s6047/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026.","Actual read bounds, precise pinpoints, and limits":"Selected complete (d)(1)–(2), (g), (h) and relevant source/amendment notes read. §6047(d)’s issuer reporting rule and §6050Y coordination identified; complete reporting obligations excluded. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S022","urls":["https://uscode.house.gov/us/usc/119-134/t26/s3405/","https://uscode.house.gov/us/usc/119-134/t26/s3405/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S022","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §3405, Special rules for pensions, annuities, and certain other deferred income. https://uscode.house.gov/us/usc/119-134/t26/s3405/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-134, October 20, 2026.","Actual read bounds, precise pinpoints, and limits":"Read (a)–(e)(13). Relied on (d), (e)(1), (e)(6), and (e)(8) to distinguish reporting/withholding classification, payor duties, cash limitations, and substantive income treatment. No full withholding determination or rate calculation. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S023","urls":["https://uscode.house.gov/currency.html","https://uscode.house.gov/classification/tables.html","https://uscode.house.gov/classification/tbl119cd_2nd.html","https://uscode.house.gov/currency.html?utm_source=chatgpt.com","https://uscode.house.gov/classification/tables.html?utm_source=chatgpt.com","https://uscode.house.gov/classification/tbl119cd_2nd.html?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S023","Issuer, instrument, and complete literal HTTPS URL":"OLRC, Currency and Updating; Classification Tables; 2026 classification table. https://uscode.house.gov/currency.html; https://uscode.house.gov/classification/tables.html; https://uscode.house.gov/classification/tbl119cd_2nd.html","Version, legal status, and effectiveness":"Publisher currency and classification metadata; not substantive tax authority.","Actual read bounds, precise pinpoints, and limits":"Currency and table-explanation pages read; 2026 table header and entire Title 26 block read. Not the entire classification table or a full session-law audit. \nUS Code\n+2"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}},{"source_id":"R036-P1-S024","urls":["https://uscode.house.gov/us/usc/119-124/t26/s807/","https://uscode.house.gov/us/usc/119-124/t26/s807/?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"R036-P1-S024","Issuer, instrument, and complete literal HTTPS URL":"Congress; OLRC, 26 U.S.C. §807 notes, P.L. 115-97 §13517(c). https://uscode.house.gov/us/usc/119-124/t26/s807/","Version, legal status, and effectiveness":"Retrieved text through P.L. 119-124, October 15, 2026. Enactment December 22, 2017; specified amendments apply to taxable years beginning after December 31, 2017.","Actual read bounds, precise pinpoints, and limits":"Read complete §13517(c)(1)–(3) effective-date, transition, and transition-relief note. Not whole §807. The reserve transition was not imported into policyholder loan taxation. \nuscode.house.gov"},"coordinator_verification_status":"original_researcher_attributed_not_freshly_reopened","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","scope":"Whole saved source record read/reconciled; no fresh body certification. Preserve original exact read/version/secondary/currentness/PDF/judicial/contract/application limitations.","fresh_selected_evidence":[],"new_failure_evidence":[],"all_original_holds_retained":true}}],"coverage":[{"topic":"1 — Complete material §72 provisions","researcher_record":{"Requested item / subquestion":"1 — Complete material §72 provisions","Status":"Answered, selected complete provisions","Finding and evidence crosswalk":"S001 read bounds; C005, C053–C086; B05–B14, B20.","Missing evidence or exact next permissible inquiry":"Actual application unresolved; no claim of whole-§72 reading."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"1 — Actual life-contract definition","researcher_record":{"Requested item / subquestion":"1 — Actual life-contract definition","Status":"Answered","Finding and evidence crosswalk":"C002–C034; S003, S006, S014, S024; B01–B02.","Missing evidence or exact next permissible inquiry":"Qualification facts held; targeted further published qualification guidance only."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"1 — Actual MEC definition and seven-pay computation","researcher_record":{"Requested item / subquestion":"1 — Actual MEC definition and seven-pay computation","Status":"Answered statutory framework","Finding and evidence crosswalk":"C035–C048; S002; B03, B17.","Missing evidence or exact next permissible inquiry":"Actual actuarial test and contract facts held."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"1 — Investment and distinct value definitions","researcher_record":{"Requested item / subquestion":"1 — Investment and distinct value definitions","Status":"Answered","Finding and evidence crosswalk":"C003–C005, C013, C046, C056, C058, C094; S001–S004.","Missing evidence or exact next permissible inquiry":"Actual measurement inputs absent; no interchange of definitions."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"1 — Nested benefit-reduction/material-change rules","researcher_record":{"Requested item / subquestion":"1 — Nested benefit-reduction/material-change rules","Status":"Answered","Finding and evidence crosswalk":"C015–C020, C038–C045, C069; S002–S003, S011.","Missing evidence or exact next permissible inquiry":"Actual reduction/change/rider predicates held."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"1 — Issue/exchange/grandfather triggers","researcher_record":{"Requested item / subquestion":"1 — Issue/exchange/grandfather triggers","Status":"Answered with specific partial issue","Finding and evidence crosswalk":"C007, C028–C034, C044, C049–C052, C060, C070; S001–S003, S006, S014.","Missing evidence or exact next permissible inquiry":"§7702(i)’s post-2020 legacy cross-reference remains partial; next inquiry is published Treasury/IRS interpretation."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"1 — Aggregation","researcher_record":{"Requested item / subquestion":"1 — Aggregation","Status":"Answered statutory rules","Finding and evidence crosswalk":"C012, C042, C070, C092, C095; B11.","Missing evidence or exact next permissible inquiry":"Additional regulatory anti-abuse application not presumed; exact statutory grouping facts held."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"1 — No uniform permanent-policy/loan/balance inference","researcher_record":{"Requested item / subquestion":"1 — No uniform permanent-policy/loan/balance inference","Status":"Answered boundary","Finding and evidence crosswalk":"C002, C035, C054–C066, comparison table.","Missing evidence or exact next permissible inquiry":"No actual classification supplied."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"2 — Non-MEC versus MEC","researcher_record":{"Requested item / subquestion":"2 — Non-MEC versus MEC","Status":"Answered","Finding and evidence crosswalk":"C035, C054–C059, C070, C078–C082; S001–S002.","Missing evidence or exact next permissible inquiry":"Application unresolved without qualification/MEC evidence."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"2 — Annuity and excluded-contract comparison","researcher_record":{"Requested item / subquestion":"2 — Annuity and excluded-contract comparison","Status":"Answered to necessary boundary","Finding and evidence crosswalk":"C026, C060, C071, C073–C077, C083–C085.","Missing evidence or exact next permissible inquiry":"Full annuity/retirement analysis excluded; B02, B20 identify permitted next inquiry."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"2 — Unknown/nonqualifying category","researcher_record":{"Requested item / subquestion":"2 — Unknown/nonqualifying category","Status":"Answered conditional rule","Finding and evidence crosswalk":"C023–C025; S003 §7702(g); B01.","Missing evidence or exact next permissible inquiry":"Actual failure and annual/catch-up amounts unresolved."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"2 — Loan and collateral assignment/pledge","researcher_record":{"Requested item / subquestion":"2 — Loan and collateral assignment/pledge","Status":"Answered statutory trigger","Finding and evidence crosswalk":"C054–C059, C071–C072; B06–B07.","Missing evidence or exact next permissible inquiry":"Character, affected portion, timing, and exceptions unknown."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"2 — Cash distribution ordering and investment recovery","researcher_record":{"Requested item / subquestion":"2 — Cash distribution ordering and investment recovery","Status":"Answered conditional rule","Finding and evidence crosswalk":"C005, C016–C020, C053–C061, C067–C075.","Missing evidence or exact next permissible inquiry":"Receipt/start-date/aggregation inputs absent."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"2 — Complete surrender/refund/maturity","researcher_record":{"Requested item / subquestion":"2 — Complete surrender/refund/maturity","Status":"Answered","Finding and evidence crosswalk":"C061–C064; S001, S013, S016–S018.","Missing evidence or exact next permissible inquiry":"Actual amount received and prior investment unknown."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"2 — Lapse/termination/discharge and zero-cash events","researcher_record":{"Requested item / subquestion":"2 — Lapse/termination/discharge and zero-cash events","Status":"Partial public-law coverage; unresolved application","Finding and evidence crosswalk":"C064–C066; B08–B10.","Missing evidence or exact next permissible inquiry":"Need event-specific published authority and absent event mechanics; no case or record query."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"2 — Separate cash, income, liability, policy debt, and later event","researcher_record":{"Requested item / subquestion":"2 — Separate cash, income, liability, policy debt, and later event","Status":"Answered analytical distinction","Finding and evidence crosswalk":"C005, C057–C058, C064–C066, C103, C107–C113.","Missing evidence or exact next permissible inquiry":"No actual reconciliation possible."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"3 — MEC additional-tax base/rate","researcher_record":{"Requested item / subquestion":"3 — MEC additional-tax base/rate","Status":"Answered","Finding and evidence crosswalk":"C078; S001 §72(v)(1).","Missing evidence or exact next permissible inquiry":"Includible amount unknown; E0."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"3 — Age/disability/periodic-payment exceptions","researcher_record":{"Requested item / subquestion":"3 — Age/disability/periodic-payment exceptions","Status":"Answered statutory predicates","Finding and evidence crosswalk":"C079–C082; S001 §§72(v)(2), (m)(7); B12.","Missing evidence or exact next permissible inquiry":"Actual taxpayer/event evidence held."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"3 — Periodic-payment modification/recapture","researcher_record":{"Requested item / subquestion":"3 — Periodic-payment modification/recapture","Status":"Partial","Finding and evidence crosswalk":"C084, C086; S001 versus S019.","Missing evidence or exact next permissible inquiry":"Published §72(v)-specific authority resolving instruction/statute tension not established."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"3 — Necessary interest-deduction provisions","researcher_record":{"Requested item / subquestion":"3 — Necessary interest-deduction provisions","Status":"Answered statutory gates; application excluded/held","Finding and evidence crosswalk":"C087–C099; S004–S006; B13.","Missing evidence or exact next permissible inquiry":"Full deduction tracing, business ownership, rates, elections, and calculations held."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"3 — No borrowing prohibition from deduction restriction","researcher_record":{"Requested item / subquestion":"3 — No borrowing prohibition from deduction restriction","Status":"Answered boundary","Finding and evidence crosswalk":"C091, C099–C100.","Missing evidence or exact next permissible inquiry":"Contractual rights and insurance consequences excluded."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"3 — No §72(p), consumer-loan, or death-benefit importation","researcher_record":{"Requested item / subquestion":"3 — No §72(p), consumer-loan, or death-benefit importation","Status":"Answered boundary","Finding and evidence crosswalk":"C065–C066, C077, C082, C105, C112.","Missing evidence or exact next permissible inquiry":"Other components and full death/COD regimes excluded."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"4 — Necessary final regulations","researcher_record":{"Requested item / subquestion":"4 — Necessary final regulations","Status":"Answered selected reading; partial original-history verification","Finding and evidence crosswalk":"S012–S015; C029, C061, C073, C102.","Missing evidence or exact next permissible inquiry":"Original §1.1035-1 issuance/effectiveness and complete old-T.D. histories not verified."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"4 — Published IRS interpretation and modification status","researcher_record":{"Requested item / subquestion":"4 — Published IRS interpretation and modification status","Status":"Answered","Finding and evidence crosswalk":"S016–S018; C062–C064.","Missing evidence or exact next permissible inquiry":"No universal loan-lapse conclusion extrapolated from a loan-free ruling situation."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"4 — Public instructions, version, fields, reporting function","researcher_record":{"Requested item / subquestion":"4 — Public instructions, version, fields, reporting function","Status":"Answered selected material body","Finding and evidence crosswalk":"S019; C086, C109–C112.","Missing evidence or exact next permissible inquiry":"Exact issuance day not established; no whole-document/form-pixel claim."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"4 — Reporting/withholding authority","researcher_record":{"Requested item / subquestion":"4 — Reporting/withholding authority","Status":"Answered boundary","Finding and evidence crosswalk":"S020–S022; C106–C108, C113.","Missing evidence or exact next permissible inquiry":"Actual obligation and full reporting rules held."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"4 — Primary-source status/access/read bounds","researcher_record":{"Requested item / subquestion":"4 — Primary-source status/access/read bounds","Status":"Answered with disclosed gaps","Finding and evidence crosswalk":"Source register, C001, source-read/failure log.","Missing evidence or exact next permissible inquiry":"Compilation dates are not a complete later-law or judicial audit."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"5 — Provision-specific comparison","researcher_record":{"Requested item / subquestion":"5 — Provision-specific comparison","Status":"Answered","Finding and evidence crosswalk":"Section 3; C002–C113 as linked there.","Missing evidence or exact next permissible inquiry":"All actual applications remain unresolved."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"5 — At least twelve substantive branches","researcher_record":{"Requested item / subquestion":"5 — At least twelve substantive branches","Status":"Answered: B01–B20","Finding and evidence crosswalk":"Each branch contains rule, C/S links, missing evidence, adverse inference, next inquiry.","Missing evidence or exact next permissible inquiry":"None populated with an identifying entry."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"5 — Wholly blank evidence/audit worksheet","researcher_record":{"Requested item / subquestion":"5 — Wholly blank evidence/audit worksheet","Status":"Answered","Finding and evidence crosswalk":"Section 5.","Missing evidence or exact next permissible inquiry":"All entry cells deliberately blank."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"5 — No borrowing/surrender/lapse/replacement recommendation","researcher_record":{"Requested item / subquestion":"5 — No borrowing/surrender/lapse/replacement recommendation","Status":"Answered scope requirement","Finding and evidence crosswalk":"C100; B16, B18.","Missing evidence or exact next permissible inquiry":"Suitability and contractual consequences excluded."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"6 — Optional mathematical illustration","researcher_record":{"Requested item / subquestion":"6 — Optional mathematical illustration","Status":"Omitted with reason","Finding and evidence crosswalk":"E0; Section 6.","Missing evidence or exact next permissible inquiry":"Missing trigger, measurement, ordering, aggregation, and convention inputs."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"6 — No actual deadline/value/deduction/tax bill","researcher_record":{"Requested item / subquestion":"6 — No actual deadline/value/deduction/tax bill","Status":"Answered scope requirement","Finding and evidence crosswalk":"E0; no application numbers supplied.","Missing evidence or exact next permissible inquiry":"Statutory dates and thresholds are stated only as law."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"Parent holds and other A036 components","researcher_record":{"Requested item / subquestion":"Parent holds and other A036 components","Status":"Excluded with reason","Finding and evidence crosswalk":"C077, C100, C105, C113; B13, B15–B16.","Missing evidence or exact next permissible inquiry":"Retirement, equity, family help, savings/asset sales, other taxes, nonfederal law, insurer practices, and full remedies/reporting remain reserved."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}},{"topic":"Independent review / acceptance","researcher_record":{"Requested item / subquestion":"Independent review / acceptance","Status":"Not performed or claimed","Finding and evidence crosswalk":"Researcher self-check below.","Missing evidence or exact next permissible inquiry":"No component, parent, operational, or publication acceptance."},"raw_table_index":12,"coordinator_acceptance":"scoped_coordinator_review_with_retained_holds_not_parent_acceptance","coordinator_review":{"at":"2026-10-29T09:14:28.212258+00:00","identity":"delegated_coordinator_not_independent","source_checks":"[internal evidence reference]","original_gap_text_unchanged":true}}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[{"id":"R036-P1-SCOPED-REVIEW","status":"scoped_coordinator_review_with_material_primary_access_currentness_application_holds_not_parent_acceptance","at":null},{"id":"R036-P1-VALIDATION-G01","status":"validation_only_UNSENT_retained_hold_not_new_material_error","at":null},{"id":"R036-P1-VALIDATION-G02","status":"validation_only_UNSENT_retained_hold_not_new_material_error","at":null},{"id":"R036-P1-VALIDATION-G03","status":"validation_only_UNSENT_retained_hold_not_new_material_error","at":null},{"id":"R036-P1-VALIDATION-G04","status":"validation_only_UNSENT_retained_hold_not_new_material_error","at":null},{"id":"R036-P1-VALIDATION-G05","status":"validation_only_UNSENT_retained_hold_not_new_material_error","at":null},{"id":"R036-P1-VALIDATION-G06","status":"validation_only_UNSENT_retained_hold_not_new_material_error","at":null},{"id":"R036-P1-VALIDATION-PRIMARY72","status":"validation_only_UNSENT_source_access_hold_not_substantive_error","at":null},{"id":"R036-P1-VALIDATION-PRIMARY7702A","status":"validation_only_UNSENT_source_access_hold_not_substantive_error","at":null},{"id":"R036-P1-VALIDATION-PRIMARY264","status":"validation_only_UNSENT_source_access_hold_not_substantive_error","at":null}]}