"Since the initial proposal, there have been repeated calls from policy groups and employee benefits practitioners for the IRS to revise its interpretation of the 10-year rule and remove the simultaneous application. A common complaint was that the interpretation was contrary to the congressional intent of the rule.  The IRS said it reviewed the comments expressing concerns about the 10-year rule but 'determined that the final regulations should retain the provision in the proposed regulations requiring such a beneficiary to continue receiving annual payments.' "

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