The FAQ published by the IRS on its web site provided examples of calculations that differ in some ways from what might have been expected from Rev. Rul. 2002-62 and standard IRS actuarial assumptions. Specifically, the FAQ differed in two ways:
- The amortization in the FAQ was based on end-of-period payments, while the Rev. Rul. suggests that beginning-of-period payments would be more appropriate. (If the first distribution is made at the end of 12 months, then it is impossible to say whether the interest rate used to determine the distribution is not more than 120 percent of the federal mid-term rate "for either of the two months immediately preceding the month in which the distribution begins," as required by section 2.09(c) of the Rev. Rul.) Answering "Yes" to "Use Methodology from IRS FAQ will therefore calculate amortized payments made at the end of each year, while answering "No" will result in amortized payments made at the beginning of each year.
- The annuitization in the FAQ was based on an actuarial assumption known as a "curtate" annuity, while the usual IRS assumption is for a "complete" annuity. (Briefly, a "curtate" annuity pays nothing to the annuitant for the year in which the annuitant dies, while a "complete" annuity makes a proportionate payment to the annuitant in the year of death.) Answering "Yes" to "Use Methodology for IRS FAQ" will therefore result in an annuity factor based on a "curtate" annuity, while answering "No" will result in an annuity factor based on a "complete" annuity."