Priv. Ltr. Rul. 201330016 (Apr. 16, 2013)

(taxpayer's mother died naming taxpayer as beneficiary of non-qualified annuities that had not been annuitized; taxpayer elected to receive payout over taxpayer's life expectancy, but learned that she could obtain new annuity from a company with a higher payout than would be received from issuers of inherited annuities; taxpayer structured tax-deferred exchange under I.R.C. Sec. 1035 to obtain annuity with higher payout from different company with the money from original annuities sent directly to the different company; IRS approved transaction as tax-deferred if all requirements of I.R.C. Sec. 1035 satisfied; ruling provides additional option to taxpayers that inherit annuities other than either electing to annuitize the contract within 12 months or taking all of the money out within five years and pay tax on any deferred gains, or, in this instance since taxpayer was not spouse of decedent, wait at least five years and then liquidating the contract).