Rev. Rul. 67-361

An organization described in section 501(c)(3) of the Internal Revenue Code of 1954 and exempt from Federal income tax under section 501(a) issued nontransferable, nonforfeitable annuity contracts directly to its employees and established a separately funded retirement reserve to provide the annuity benefits specified under the contracts. This reserve is subject to the supervision of the state insurance department.

Held , the organization will be considered to have purchased annuity contracts for its employees and the provisions of section 403(b) of the Code will be applicable provided the requirements of that section are met in all respects.