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I can't answer your question directly at this time but I can say from the wording in my Pruco contract as issued in 1982 that it was issued as an Individual Retirement Annuity (IRA) within the meaning of Section 408 (b) of IRS Code of 1954 as amended. In 2005 I received an endorsement which reflected key Internal Revenue Code provisions applicable to tax-qualifies IRAs, as modified by the economic growth and Tax Relief Reconciliation Act. Thanks.

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