Revenue Ruling 2009-13 has proven “contentious,” said Stephan Leimberg, chief executive officer of Leimberg Information Services Inc., Bryn Mawr, Pa., and Thomas Commito, director of sales concepts at Lincoln Financial Distributors, Hartford, during a recent panel in St. Petersburg, Fla. The Ruling addresses tax consequences of surrender or sale of a life policy to a person who lacks an insurable interest in the contract.

What’s contentious? The lack of guidance concerning the cost-of-insurance calculation when determining the amount of ordinary or capital gain in certain transactions, said the panelists.

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