Special rule where lump sum paid in connection with commencement of annuity payments
If, in connection with the commencement of annuity payments under any qualified employer retirement plan, the taxpayer receives a lump-sum payment—
(i)#
such payment shall be taxable under subsection (e) as if received before the annuity starting date, and
(ii)#
the investment in the contract for purposes of this paragraph shall be determined as if such payment had been so received.