It doesn't have to involve a contribution to an IRA and would not involve an IRA if the IRA/SEP/SIMPLE box is not marked on the Form 1099-R. The code W Form 1099-R suggests that a QLAC was purchased from the cash value or surrender value of that annuity was used to purchase a QLAC, so perhaps this is being treated as a combined arrangement rather than a directly purchase the long-term care insurance. I'm not sure that it matters much that it implies that the long-term care insurance is combined with a $0-value annuity, but it does seem odd.
Code W was introduced in 2010 along with QLACs.
