[Code of Federal Regulations]
[Title 26, Volume 1]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.264-2]

[Page 563]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.264-2  Single premium life insurance, endowment, or annuity 
contracts.

    Amounts paid or accrued on indebtedness incurred or continued, 
directly or indirectly, to purchase or to continue in effect a single 
premium life insurance or endowment contract, or to purchase or to 
continue in effect a single premium annuity contract purchased (whether 
from the insurer, annuitant, or any other person) after March 1, 1954, 
are not deductible under section 163 or any other provision of chapter 1 
of the Code. This prohibition applies even though the insurance is not 
on the life of the taxpayer and regardless of whether or not the 
taxpayer is the annuitant or payee of such annuity contract. A contract 
is considered a single premium life insurance, endowment, or annuity 
contract, for the purposes of this section, if substantially all the 
premiums on the contract are paid within four years from the date on 
which the contract was purchased, or if an amount is deposited after 
March 1, 1954, with the insurer for payment of a substantial number of 
future premiums on the contract.