Q. What about IRC Section 72(q) for Non-Qualified Tax-Deferred Annuities? 

A. Internal Revenue Bulletin 2004-15 states: “The IRS and Treasury believe that because these provisions were enacted for the same purpose it is appropriate to apply the same methods to determine whether a distribution is part of a series of substantially equal periodic payments. Therefore, taxpayers may use one of the methods set forth in Notice 89-25, as modified by Rev. Rul. 2002-62, to determine whether a distribution from a non-qualified annuity contract is part of a series of substantially equal periodic payments under § 72(q)(2)(D).”
For additional details, see the Discussion Post ‘IRS Helps Again’.