<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Saturday, September 26, 2015 10:46 AM</td></tr><tr><td>To:</td><td>Halperin, Alan S</td></tr><tr><td>Subject:</td><td>Re:</td></tr></table>

why is not semi annual payments with the last paymen= on the anniversary date qualify, it was only the choice of an=versary or tax year?

On Sat, Sep 26, 2015 at 6:41 AM, Halperin, Alan S <a
wrote:

An annuity paid on the anniversary date is an annual annuity (and probably =he last annuity payment on other types of payment schedules).

Alan S. Halperin I Partner Paul, Weiss, Rifkind, Wharton & Garrison =LP 1285 Avenue of the Americas | New York,=C2 <u>NY 10019-6064</u>

<http://www.paulweiss.com>
From: jeffrey E.
Sent: Saturday, September 26, 2015 1:09 AM
To: Halperin, Alan S
Subject:

https://www.law.cornell.edu/cfr/text/26/25.2702-3 <https://www.law.cornelLedu/cfr/text/26/25.2702=3> =C2 i only see the limitation of the 105 day look back to be=based on anniversary date. i dont see the annual min req that =ou mentioned.

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please =ote

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