(decedent was grantor and sole beneficiary of annuity trust, and served as co-trustee with some of her children; decedent held 50 percent of trust's voting rights; decedent transferred two rental properties to trust in return for 180-month annuity that were subject to mortgages; trust paid mortgages, but did non assume mortgages; trust language allowed trust income in excess of periodic payment to be distributed to decedent or be accumulated in trust; upon later of end of term or decedent's death; trust to pass to decedent's surviving children or grandchildren; decedent, as trustee, managed properties after transfer; decedent filed Form 709 reporting transfer of properties with portion of value retained; decedent also trustee as sole beneficiary of "residence trust" with trust terms giving decedent right to use trust property as personal residence and right to receive income from trust; Form 709 filed reporting transfer of residence and reporting portion retained; decedent later amended trust and upon decedent's death, residence transferred to charitable remainder trust at decedent's prior direction; decedent's Form 706 excluded properties from estate and claimed charitable deduction; IRS argued for estate inclusion of properties transferred to annuity trust via I.R.C. Sec. 2036(a); court agreed with IRS; annuity trusts not sufficiently similar to FLPs such that Estate of Bongard v. Comr., 124 T.C. 95 (2005) inapplicable; not sufficient non-tax reasons for transfer present; full value of residence included in decedent's estate under I.R.C. Sec. 2036(a); estate not entitled to charitable deduction because term of residence trust ended before decedent's death and should have been distributed under terms of trust to children and grandchildren rather than as directed by will).