The Internal Revenue Service ("IRS") recently issued two Notices concerning life insurance contracts. In Notice 2009-47, the IRS requested comments on a proposed safe harbor regarding the application of Internal Revenue Code ("IRC") Sections 7702 (definition of life insurance) and 7702A (definition of modified endowment contracts) to life insurance contracts that continue after an insured attains age 100. The IRS also requested comments in situations where a life insurance contract matures after the insured has attained age 100.

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