633 / Is a death or survivor benefit under a tax sheltered annuity includable in an employee's gross estate if the decedent died after 1984?

The value of an annuity or other payment receivable under a tax-sheltered annuity (“TSA”) by the beneficiary of a deceased TSA annuitant is includable in the annuitant’s estate under the rules discussed in Q 620 to Q 629.In reading those rules, remember that any contribution to the purchase of the annuity made by the decedent’s employer or former employer is considered to be contributed by the decedent if made by reason of his or her employment.¹ Note that in the case of payments received as insurance on the life of a decedent ( Q 4029), estate taxation is determined under the rules of IRC Section 2042 ( Q 80 to Q 93), not under IRC Section 2039.