The purchase of an annuity contract entitling the purchaser to a specified annuity during the remainder of his life, together with a so-called "single premium life policy" issued without a physical examination of the purchaser and providing for the payment of a given sum to a named beneficiary on the purchaser's death, insofar as the policy is concerned constitutes a transfer intended to take effect in possession or enjoyment at or after death and is subject to the Inheritance Tax Law, if it appears that the policy would not have been issued without the contract. In such case, the insurance exemption provided in Revenue and Taxation Code Section 13724 is not allowable against the proceeds of the policy.
NOTE: Reference: Sections 13721 to 13724, inclusive, 13861 and 13861.5, Revenue and Taxation Code.
Cal. Code Regs. Tit. 18, § 13644.1