IDS LIFE OF NEW YORK ACCOUNT 4
486BPOS, 1994-04-26
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<PAGE>
PAGE 1
                SECURITIES AND EXCHANGE COMMISSION

                      Washington, D.C.  20549

                             FORM N-4

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933

     Post-Effective Amendment No.  21  (File No. 2-78194)       X  

                              and/or

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940

     Amendment No.  14  (File No. 811-3500)                     X  

                  IDS LIFE OF NEW YORK ACCOUNT 4
                  IDS LIFE OF NEW YORK ACCOUNT 5
                  IDS LIFE OF NEW YORK ACCOUNT 6
                  IDS LIFE OF NEW YORK ACCOUNT 9
                  IDS LIFE OF NEW YORK ACCOUNT 10
                  IDS LIFE OF NEW YORK ACCOUNT 11
___________________________________________________________________
                    (Exact Name of Registrant)

              IDS Life Insurance Company of New York
___________________________________________________________________
                        (Name of Depositor)

          20 Madison Avenue Extension, Albany, NY  12203 
___________________________________________________________________
  (Address of Depositor's Principal Executive Offices) (Zip Code)

Depositor's Telephone Number, including Area Code (612) 671-3678  

   Mary Ellyn Minenko, IDS Tower 10, Minneapolis, MN  55440-0010
___________________________________________________________________
              (Name and Address of Agent for Service)

It is proposed that this filing will become effective:

      immediately upon filing pursuant to paragraph (b) of Rule 486
  X   on April 29, 1994, pursuant to paragraph (b) of Rule 486
      60 days after filing pursuant to paragraph (a) of Rule 486
      on (date) pursuant to paragraph (a) of Rule 486

The Registrant has registered an indefinite number or amount of
securities under the Securities Act of 1933 pursuant to Section 
24-f of the Investment Company Act of 1940.  Registrant's Rule 
24f-2 Notice for its most recent fiscal year was filed on or about
February 25, 1994.

<PAGE>
PAGE 2
<TABLE>
<CAPTION>
                                    CROSS REFERENCE SHEET

Cross reference sheet showing location in the prospectus of the information called
for by the items enumerated in Part A and B of Form N-4.

Negative answers omitted from prospectus are so indicated.

             PART A                                  PART B

                                                             Page Number in
                  Page Number                                Statement of
  Item No.        in Prospectus              Item No.        Additional Information
   <C>             <C>                        <C>             <C>
   1               3                          15              33

   2               5-6                        16              34
  
   3(a)            8-10                       17(a)           NA
    (b)            6-8                          (b)           NA
                                                (c)           31*
   4(a)            10-11
    (b)            12-13                      18(a)           NA
    (c)            11-12                        (b)           NA
                                                (c)           40
   5(a)            3,31                         (d)           NA
    (b)            13                           (e)           NA
    (c)            13-14                        (f)           40
    (d)            3,14 
    (e)            30                         19(a)           40
    (f)            NA                           (b)           18-19*
 
   6(a)            17-19                      20(a)           40
    (b)            18-19                        (b)           40
    (c)            19                           (c)           40
    (d)            NA                           (d)           NA
    (e)            14
    (f)            NA                         21(a)           35-37
                                                (b)           35-37
   7(a)            15                          
    (b)            13,21-23                   22              37-38
    (c)            14,19                    
    (d)            3                          23(a)           41-48
                                                (b)           49-64
   8(a)            26-27  
    (b)            15-16
    (c)            26-27
    (d)            26-27  
    (e)            27
    (f)            27

   9(a)            25
    (b)            25

  10(a)            15,16-17,19-20
    (b)            19-20
    (c)            15,16-17,19-20
    (d)            31

  11(a)            23-24
    (b)            NA
    (c)            23-24
    (d)            16
    (e)            6

  12(a)            27-30
    (b)            6
    (c)            NA

  13               NA

  14               32

*Designates page number in the prospectus, which is hereby incorporated by reference
in this Statement of Additional Information.
</TABLE>
<PAGE>
PAGE 3
IDS Life of New York Variable Retirement and Combination Retirement
Annuities

Prospectus
April 29, 1994

This prospectus describes two individual deferred annuity contracts
offered by IDS Life Insurance Company of New York (IDS Life of New
York).  The Variable Retirement Annuity (VRA) is a deferred annuity
contract in which a single purchase payment accumulates on a
variable basis and retirement benefits are paid to the owner.  It
can be used for qualified and nonqualified retirement plans.  The
Combination Retirement Annuity (CRA) is a deferred annuity contract
in which installment purchase payments are accumulated on a fixed
and/or variable basis and provides for retirement payments to the
owner.  It is available only for qualified plans.

New Variable Retirement Annuity contracts are not currently being
offered.

IDS Life of New York Accounts 4, 5, 6, 9, 10 and 11  

Sold by:  IDS Life Insurance Company of New York
        20 Madison Ave. Extension
        Albany, NY 12203
        Telephone: 518-869-8613.

THIS PROSPECTUS CONTAINS THE INFORMATION ABOUT THE VARIABLE
ACCOUNTS THAT YOU SHOULD KNOW BEFORE INVESTING.  Refer to "The
variable accounts" in this prospectus.

THE PROSPECTUS IS ACCOMPANIED OR PRECEDED BY THE RETIREMENT ANNUITY
MUTUAL FUND PROSPECTUS FOR IDS LIFE AGGRESSIVE GROWTH FUND, IDS
LIFE INTERNATIONAL EQUITY FUND, IDS LIFE CAPITAL RESOURCE FUND, IDS
LIFE MANAGED FUND, INC., IDS LIFE SPECIAL INCOME FUND, INC. AND IDS
LIFE MONEYSHARE FUND, INC.  PLEASE KEEP THESE PROSPECTUSES FOR
FUTURE REFERENCE.

THESE SECURITIES HAVE NOT BEEN APPROVED OR DISAPPROVED BY THE
SECURITIES AND EXCHANGE COMMISSION, OR ANY STATE SECURITIES
COMMISSION, NOR HAS THE SECURITIES AND EXCHANGE COMMISSION OR
ANY STATE SECURITIES COMMISSION PASSED UPON THE ACCURACY OR
ADEQUACY OF THIS PROSPECTUS.  ANY REPRESENTATION TO THE CONTRARY
IS A CRIMINAL OFFENSE.

IDS LIFE OF NEW YORK IS NOT A BANK, AND THE SECURITIES IT OFFERS
ARE NOT DEPOSITS OR OBLIGATIONS OF, OR GUARANTEED OR ENDORSED BY
ANY BANK NOR ARE THEY INSURED BY THE FEDERAL DEPOSIT INSURANCE
CORPORATION, THE FEDERAL RESERVE BOARD OR ANY OTHER AGENCY.

A Statement of Additional Information (SAI) dated April 29, 1994
(incorporated by reference into this prospectus) has been filed
with the Securities and Exchange Commission (SEC), and is available
without charge by contacting IDS Life of New York at the telephone
number above or by completing and sending the order form on the
last page of this prospectus.  The table of contents of the SAI is
on the last page of this prospectus.
<PAGE>
PAGE 4
                         Table of Contents
   
Key terms..................................................... 
The Variable and Combination Retirement Annuities in brief.... 
Expense summary...............................................
Condensed financial information...............................
Financial statements..........................................
Performance information.......................................
The variable accounts.........................................
The funds.....................................................
     Aggressive Growth Fund...................................
     International Equity Fund................................
     Capital Resource Fund....................................
     Managed Fund.............................................
     Special Income Fund......................................
     Moneyshare Fund..........................................
The fixed account.............................................
Buying your annuity...........................................
     Setting the retirement date..............................
     Beneficiary..............................................
     Two ways to make purchase payments.......................
Charges.......................................................
     Contract administrative charge...........................
     Mortality and expense risk fee...........................
     Surrender charge.........................................
Valuing your investment.......................................
     Number of units..........................................
     Accumulation unit value..................................
     Net investment factor....................................
     Factors that affect variable account
     accumulation units.......................................
Making the most of your annuity...............................
     Automated dollar - cost averaging........................
     Transferring money between accounts......................
     Transfer policies........................................
     Two ways to request a transfer or a surrender............
Surrendering your contract....................................
     Surrender policies.......................................
     Receiving payment when you request a surrender...........
TSA special surrender provisions..............................
Changing ownership............................................
Benefits in case of death.....................................
The annuity payout period.....................................
     Annuity payout plans.....................................
     Death after annuity payouts begin........................
     Transfers between accounts after annuity
     payouts begin............................................
Taxes.........................................................
Voting rights.................................................
About IDS Life of New York....................................
Regular and special reports...................................
Table of contents of the Statement of
Additional Information........................................
    
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PAGE 5
Key terms

These terms can help you understand details about your annuity.

Annuity - A contract purchased from an insurance company that
offers tax-deferred growth of the contract owner's investment until
earnings are withdrawn, and that can be tailored to meet the
specific needs of the individual during retirement.

Accumulation unit - A measure of the value of each variable account
before annuity payouts begin. 
                                                                    
Annuitant - The person on whose life or life expectancy the payouts
are based.

Annuity payouts - An amount paid at regular intervals under one of
several plans available to the owner and/or any other payee.  This
amount may be paid on a variable or fixed basis or a combination of
both. 

Annuity unit - A measure of the value of each variable account used
to calculate the annuity payouts you receive. 

Beneficiary - The person designated to receive annuity benefits in
case of the owner's or annuitant's death.

Close of business - When the New York Stock Exchange (NYSE) closes,
normally 4 p.m. Eastern time.

Code - Internal Revenue Code of 1986, as amended.
   
Contract value - The total value of your annuity before any
applicable surrender charge and any contract administrative charge
have been deducted.
    
Contract year - A period of 12 months, starting on the effective
date of your contract and on each anniversary of the effective
date.

Fixed account - An account to which you may allocate purchase
payments.  Amounts allocated to this account earn interest at rates
that are declared periodically by IDS Life of New York.  

IDS Life of New York - In this prospectus, "we," "us," "our," and
"IDS Life of New York" refer to IDS Life Insurance Company of New
York.

Mutual funds (funds) - Six IDS Life Retirement Annuity mutual
funds, each with a different investment objective.  (See "The
funds.")  You may allocate your purchase payments into variable
accounts investing in shares of any or all of these funds.

Owner (you, your) - The person who controls the annuity (decides on
investment allocations, transfers, payout options, etc.).  Usually,
but not always, the owner is also the annuitant.  The owner is
responsible for taxes, regardless of whether he or she receives the
annuity's benefits.
<PAGE>
PAGE 6
Purchase payments - Payments made to IDS Life of New York for an
annuity.

Qualified annuity -  An annuity purchased for a retirement plan
that is subject to applicable federal law and any rules of the plan
itself.  These plans include:

o  Individual Retirement Annuities (IRAs)
o  Simplified Employee Pension Plans (SEPs)
o  Section 401(k) plans
o  Custodial and trusteed pension and profit sharing plans
o  Tax Sheltered Annuities (TSAs)
o  Section 457 plans

All other annuities are considered nonqualified annuities.
   
Retirement date - The date when annuity payouts are scheduled to
begin.  This date is first established when you start your
contract.  You can change it in the future.
     
Surrender charge - A deferred sales charge that may be applied if
you surrender your annuity before the retirement date.
   
Surrender value - The amount you are entitled to receive if you
surrender your annuity.  It is the contract value minus any
applicable surrender charge and contract administrative charge. 
    
Valuation date - Any normal business day, Monday through Friday,
that the NYSE is open.  The value of each variable account is
calculated at the close of business on each valuation date.

Variable accounts - Six separate accounts to which you may allocate
purchase payments; each invests in shares of one mutual fund. (See
"The variable accounts.") The value of your investment in each
variable account changes with the performance of the particular
fund.

The Variable and Combination Retirement Annuities in brief

Purpose:  The Variable and Combination Retirement Annuities are
designed to allow you to build up funds for retirement.  You do
this by making one or more investments (purchase payments) that may
earn returns that increase the value of the annuity.  Beginning at
a specified future date (the retirement date), the annuity provides
a lifetime or other forms of payouts to you or to anyone you
designate.  Depending on the choice of annuity, payouts may be
variable, fixed, or a combination of variable and fixed.
   
Ten-day free look:  You may return your annuity to your financial
planner or our Albany office within 10 days after it is delivered
to you and receive a full refund of the contract value.  No charges
will be deducted.
    
<PAGE>
PAGE 7
Accounts:  You may allocate your purchase payments among any or all
of:

o  six variable accounts, each of which invests in mutual funds
   with a particular investment objective.  The value of each
   variable account varies with the performance of the particular
   fund.  We cannot guarantee that the value at the retirement date
   will equal or exceed the total of purchase payments allocated to
   the variable accounts.  (p.)

o  one fixed account, which earns interest at rates that are
   adjusted periodically by IDS Life of New York.  (p.)  

Buying the annuity:  Your IDS personal financial planner will help
you complete and submit an application for CRA.  Applications are
subject to acceptance at our Albany office.  You may buy a non-
qualified annuity or a qualified annuity including an IRA.  
   
o  Minimum purchase payment - $600 on an annual basis.

o  Minimum installment or additional payment - $50 monthly; $23.08
   biweekly payroll deductions.

o  Maximum first-year payment(s) -
   Nonqualified:  $25,000.
   Qualified:  Two times initial annual gross premium subject to
   any restrictions.
    
o  Maximum payment for each subsequent year -
   Nonqualified:  $50,000 excluding rollovers.
   Qualified:  Two times initial annual gross premium subject to
   any restrictions.

Unlike the CRA, VRA was purchased with a single payment.  No
additional payments are allowed for VRA.  (p.)
   
Transfers:  You may redistribute your money among accounts without
charge at any time until annuity payouts begin, and once per
contract year among the variable accounts thereafter.  You may
establish automated transfers among the fixed and variable
account(s), subject to certain restrictions.  (p.)
    
Surrenders:  You may surrender all or part of your contract value
at any time before the retirement date.  You also may establish
automated partial surrenders.  Surrenders may be subject to charges
and tax penalties and may have other tax consequences; also,
certain restrictions apply.  (p.)

Changing ownership:  You may change ownership of a nonqualified
annuity by written instruction, however, such changes of non-
qualified annuities may have federal income tax consequences. 
Certain restrictions apply concerning change of ownership of a
qualified annuity.  (p.)

<PAGE>
PAGE 8
Payment in case of death:  If you or the annuitant dies before
annuity payouts begin, we will pay the beneficiary an amount at
least equal to the contract value.  (p.) 

Annuity payouts:  The contract value of your investment can be
applied to an annuity payout plan that begins on the retirement
date.  You may choose from a variety of plans to make sure that
payouts continue as long as they are needed.  If you purchased a
qualified annuity, the payout schedule must meet requirements of
the qualified plan.  Payouts may be made on a fixed or variable
basis, or both.  Total monthly payouts include amounts from each
variable account and the fixed account.  (p.) 

Taxes:  Generally your annuity grows tax deferred until you
surrender it or begin to receive payouts.  (Under certain
circumstances, IRS penalty taxes may apply.)  Even if you direct
payouts to someone else, you will still be taxed on the income if
you are the owner.  Certain state and local governments impose
premium taxes.  (p.)

Charges:  Your Variable Retirement Annuity is subject to an annual
charge of $20 and your Combination Retirement Annuity is subject to
an annual charge of $30 for contract administrative services.  The
annuities are also subject to a 1% mortality and expense risk
charge and a surrender charge.  (p.)

Expense summary

The purpose of this summary is to help you understand the various
costs and expenses associated with VRA and CRA.

You pay no sales charge when you purchase the annuities.  All costs
that you bear directly or indirectly for the variable accounts and
underlying mutual funds are shown below.  Some expenses may vary as
explained under "Contract charges."

Direct charges.  These are deducted directly from the contract
value.  They include:

Surrender charge:  Surrender charges apply if you surrender more
than a certain limited percentage of your Variable Retirement
Annuity's value within the first seven years.  The surrender charge
starts at 7% of the amount surrendered in the first contract year
and reduces by 1% each contract year thereafter, so that there is
no surrender charge in the eighth and later contract years.

With a Combination Retirement Annuity, you will pay surrender
charges on any withdrawal within the first 11 years.  The surrender
charge starts at 7% of any amount surrendered during the first five
contract years, then declines by 1% per year from 6% in the sixth
year to 1% in the 11th year.  There is no surrender charge on
amounts surrendered after the 11th year.

The surrender charge for VRA and CRA in all cases is further
limited so that it will never exceed 8.5% of aggregate purchase
payments made to the contract.
<PAGE>
PAGE 9
Annual contract administrative charge:
        Variable Retirement Annuity - $20
        Combination Retirement Annuity - $30

Indirect charges.  The variable account pays these expenses out of
its assets.  They are reflected in the variable account's daily
accumulation unit value and are not charged directly to your
account.  They include:

Mortality and expense risk fee:  1% per year, deducted from the
variable account as a percentage of the average daily net assets of
the underlying fund.

Operating expenses of underlying mutual funds:  management fees and
other expenses deducted as a percentage of average net assets as
follows: *
   
<TABLE>
<CAPTION>
                    Aggressive   International    Capital                      Special                
                     Growth         Equity        Resource       Managed       Income        Moneyshare
  <S>                 <C>           <C>             <C>          <C>           <C>            <C>
  Management fees     .65%           .89%           .65%         .65%          .65%           .54%

  Other expenses      .07            .14            .04          .04           .04            .05

  Total**             .72%          1.03%           .69%         .69%          .69%           .59%
</TABLE>
    
* Premium taxes imposed by some state and local governments are not
reflected in this table.

**Annualized operating expenses of underlying mutual funds at Dec.
31, 1993.

Example for the Variable Retirement Annuity:*

You would pay the following expenses on a $1,000 investment,
assuming a 5% annual return and surrender at the end of each time
period:
   
<TABLE>
<CAPTION>
            Aggressive   International    Capital                      Special                
             Growth         Equity        Resource       Managed       Income        Moneyshare
<S>          <C>           <C>           <C>            <C>            <C>            <C>
1 year       $ 90.43       $ 93.38       $ 90.14        $ 90.14        $ 90.14        $ 89.19

3 years       111.29        120.41        110.40         110.40         110.40         107.45

5 years       132.05        147.75        130.55         130.55         130.55         125.44

10 years      210.42        243.56        207.16         207.16         207.16         196.22
 
You would pay the following expenses on the same investment assuming no surrender:

1 year       $ 18.20       $ 21.38       $ 17.90        $ 17.90        $ 17.90        $ 16.87

3 years        56.37         66.00         55.43          55.43          55.43          52.31

5 years        97.00        113.20         95.42          95.42          95.42          90.14

10 years      210.42        243.56        207.16         207.16         207.16         196.22
</TABLE>
    
<PAGE>
PAGE 10
This example should not be considered a representation of past or
future expenses.  Actual expenses may be more or less than those
shown.
   
*In this example, the $20 annual contract administrative charge is
approximated as a .056% charge based on our average contract size.
    
Example for the Combination Retirement Annuity:*

You would pay the following expenses on a $1,000 investment,
assuming a 5% annual return and surrender at the end of each time
period:
   
<TABLE>
<CAPTION>
            Aggressive   International    Capital                      Special                
             Growth         Equity        Resource       Managed       Income        Moneyshare
<S>          <C>           <C>           <C>            <C>           <C>           <C>
1 year       $ 91.74       $ 85.85       $ 91.45        $ 91.45       $ 91.45       $ 90.50

3 years       137.21        119.33        136.34         136.34        136.34        133.46

5 years       185.49        155.31        184.04         184.04        184.04        179.19

10 years      252.17        185.76        249.04         249.04        249.04        238.51
 
You would pay the following expenses on the same investment assuming no surrender:

1 year       $ 19.61       $ 13.28       $ 19.30        $ 19.30       $ 19.30       $ 18.28

3 years        60.63         41.33         59.70          59.70         59.70         56.58

5 years       104.18         71.48        102.61         102.61        102.61         97.36

10 years      225.19        157.08        221.98         221.98        221.98        211.18
</TABLE> 
    
This example should not be considered a representation of past or
future expenses.  Actual expenses may be more or less than those
shown.
   
*In this example, the $30 annual contract administrative charge is
approximated as a .193% charge based on our average contract size.
    
Condensed financial information
(unaudited)

The following tables give per-unit information about the financial
history of each variable account.
   
<TABLE>
<CAPTION>
                                                                   Years Ended Dec. 31,                                 
                                  1993     1992     1991     1990     1989     1988     1987     1986     1985     1984 
<S>                              <C>      <C>      <C>      <C>      <C>      <C>      <C>       <C>      <C>      <C> 
Account 4 (Investing in shares of Capital Resource Fund)
Accumulation unit value at
beginning of year ............    $3.35    $3.25    $2.24    $2.25    $1.78    $1.61    $1.44    $1.33    $1.06    $1.12
Accumulation unit value at end
of year ......................    $3.43    $3.35    $3.25    $2.24    $2.25    $1.78    $1.61    $1.44    $1.33    $1.06
Number of accumulation units
outstanding at end of year
(000 omitted) ................   30,089   21,677   13,591   10,058    8,345    7,347    7,342    5,640    3,8971   2,161
________________________________________________________________________________________________________________________
Ratio of operating expense to
average net assets ...........    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%

<PAGE>
PAGE 11
Account 102 (Investing in shares of International Equity Fund)
Accumulation unit value at
beginning of period ..........    $0.98    $1.00       -        -        -        -        -        -        -        - 
Accumulation unit value at end
of period ....................    $1.29    $0.98       -        -        -        -        -        -        -        - 
Number of accumulation units
outstanding at end of period
(000 omitted) ................   21,650    3,421       -        -        -        -        -        -        -        - 
Ratio of operating expense to
average net assets ...........    1.00%    1.00%       -        -        -        -        -        -        -        - 

Account 113 (Investing in shares of Aggressive Growth Fund)
Accumulation unit value at
beginning of period ..........    $1.08    $1.00       -        -        -        -        -        -        -        - 
Accumulation unit value at end
of period ....................    $1.21    $1.08       -        -        -        -        -        -        -        - 
Number of accumulation units
outstanding at end of period
(000 omitted) ................   19,430    5,961       -        -        -        -        -        -        -        - 
Ratio of operating expense to
average net assets ...........    1.00%    1.00%       -        -        -        -        -        -        -        - 

1Account 4 includes 1,301,016 accumulation units issued in the merger of Account 1 into Account 4 on Dec. 13, 1985.
2Account 10 commenced operations on Jan. 13, 1992.
3Account 11 commenced operations on Jan. 13, 1992.

                                                                   Years Ended Dec. 31,                                 
                                  1993     1992     1991     1990     1989     1988     1987     1986     1985     1984 
Account 54 (Investing in shares of Special Income Fund)
Accumulation unit value at
beginning of year ............    $2.67    $2.46    $2.12    $2.05    $1.90    $1.74    $1.74    $1.48    $1.22    $1.09
Accumulation unit value at end
of year ......................    $3.06    $2.67    $2.46    $2.12    $2.05    $1.90    $1.74    $1.74    $1.48    $1.22
Number of accumulation units
outstanding at end of year
(000 omitted) ................   23,259   16,710   12,228   10,315    9,301    7,891    8,093    7,151    3,8304   1,603
________________________________________________________________________________________________________________________
Ratio of operating expense to
average net assets ...........    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%
Account 65 (Investing in shares of Moneyshare Fund)
Accumulation unit value at
beginning of year ............    $1.83    $1.80    $1.71    $1.61    $1.49    $1.40    $1.33    $1.26    $1.18    $1.08
Accumulation unit value at end
of year ......................    $1.86    $1.83    $1.80    $1.71    $1.61    $1.49    $1.40    $1.33    $1.26    $1.18
Number of accumulation units
outstanding at end of year
(000 omitted) ................    4,113    5,378    7,253    6,487    5,493    2,836    2,125    1,055      8655     281
________________________________________________________________________________________________________________________
Ratio of operating expense to
average net assets ...........    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%    1.00%

Simple yield6 ................    1.90%    1.77%    3.24%    6.20%    6.80%    7.30%    5.73%    4.16%    6.39%    7.51%
________________________________________________________________________________________________________________________

Compound yield6 ..............    1.92%    1.79%    3.29%    6.39%    7.03%    7.57%    5.90%    4.24%    6.59%    7.79%
________________________________________________________________________________________________________________________

Account 9 (Investing in shares of Managed Fund)
Accumulation unit value at
beginning of year ............    $1.98    $1.86    $1.45    $1.42    $1.14    $1.06    $1.01    $1.00       -        - 
Accumulation unit value at end
of year ......................    $2.21    $1.98    $1.86    $1.45    $1.42    $1.14    $1.06    $1.01       -        - 
Number of accumulation units
outstanding at end of year
(000 omitted) ................   50,761   31,828   20,105   15,292   12,248   11,920   12,219    4,030       -        - 
Ratio of operating expense to
average net assets ...........    1.00%    1.00%    1.00     1.00%    1.00%    1.00%    1.00%    1.00%       -        - 

4Account 5 includes 1,737,451 accumulation units issued in the merger of Account 2 into Account 5 on Dec. 13, 1985.
5Account 6 includes 609,594 accumulation units issued in the merger of Account 3 into Account 6 on Dec. 13, 1985.
6Net of annual contract administrative charge and mortality and expense fee.
7Account 9 commenced operations on April 30, 1986.
</TABLE>
    
<PAGE>
PAGE 12
Financial statements

The SAI dated April 29, 1994, contains:

o  complete audited financial statements of the variable accounts
   including:
    -statements of net assets as of Dec. 31, 1993;
    -statements of operations for the year ended Dec. 31, 1993;
       and
    -statements of changes in net assets for the years ended
       Dec. 31, 1993 and Dec. 31, 1992 (for Accounts 10 and
       11, the period from Jan. 13, 1992 when they commenced
       operations, to Dec. 31, 1992).

o  complete audited financial statements for IDS Life of New York,
   including:
    -consolidated balance sheets as of Dec. 31, 1993 and
       Dec. 31, 1992; and
      -related consolidated statements of income and cash flows
       for each of three years in the period ended Dec. 31, 1993.

Performance information

Performance information for the variable accounts may appear from
time to time in advertisements or sales literature.  In all cases,
such information reflects the performance of a hypothetical
investment in a particular account during a particular time period. 
Calculations are performed as follows:

Simple yield - Account 6 (investing in Moneyshare Fund):  Income
over a given seven-day period (not counting any change in the
capital value of the investment) is annualized (multiplied by 52) 
by assuming that the same income is received for 52 weeks.  This
annual income is then stated as an annual percentage return on the
investment. 

Compound yield - Account 6:  Calculated like simple yield, except
that, when annualized, the income is assumed to be reinvested.
Compounding of reinvested returns increases the yield as compared
to a simple yield.

Yield - all other accounts:  Net investment income (income less
expenses) per accumulation unit during a given 30-day period is
divided by the value of the unit on the last day of the period. 
The result is converted to an annual percentage.

Average annual total return:  Expressed as an average annual
compounded rate of return of a hypothetical investment over a
period of one, five and 10 years (or up to the life of the account
if it is less than 10 years old).  This figure reflects deduction
of all applicable charges, including the contract administrative
charge, mortality and expense risk fee and surrender charge,
assuming a surrender at the end of the illustrated period. 
Optional total return quotations may be made that do not reflect a
surrender charge deduction (assuming no surrender).  

<PAGE>
PAGE 13
Aggregate total return:  Represents the cumulative change in value
of an investment for a given period (reflecting change in an
account's accumulation unit value).  The calculation assumes
reinvestment of investment earnings.  Aggregate total return may be
shown by means of schedules, charts or graphs.

Performance information should be considered in light of the
investment objectives and policies, characteristics and quality of
the fund in which the account invests, and the market conditions
during the given time period.  Such information is not intended to
indicate future performance.  Because advertised yields and total 
return figures include all charges attributable to the annuity,
which has the effect of decreasing advertised performance, account 
performance should not be compared to that of mutual funds that 
sell their shares directly to the public.  (See the SAI for a
further description of methods used to determine yield and total
return for the accounts.)

If you would like additional information about actual performance,
contact your financial planner.

The variable accounts

Purchase payments can be allocated to any or all of the variable
accounts that invest in shares of the following funds:
   
                 IDS Life of New York Account      Established
    
Aggressive Growth Fund           11               Oct. 8, 1991
International Equity Fund        10               Oct. 8, 1991
Capital Resource Fund            4                Nov. 12, 1981
Managed Fund                     9                Feb. 12, 1986
Special Income Fund              5                Nov. 12, 1981
Moneyshare Fund                  6                Nov. 12, 1981

Each variable account meets the definition of a separate account
under federal securities laws.  Income, capital gains and capital
losses of each account are credited or charged to that account
alone.  No variable account will be charged with liabilities of any
other account or of our general business.

All variable accounts were established under New York law and are
registered together as a single unit investment trust under the
Investment Company Act of 1940 (the 1940 Act).  This registration 
does not involve any supervision of our management or investment
practices and policies by the SEC.   

The funds

Aggressive Growth Fund
Objective: capital appreciation.  Invests primarily in common stock
of small- and medium-size companies.  The fund also may invest in 
warrants or debt securities or in large well-established companies
when the portfolio manager believes such investments offer the best
opportunity for capital appreciation.

International Equity Fund
Objective: capital appreciation.  Invests primarily in common stock
of foreign issuers and foreign securities convertible into common 
<PAGE>
PAGE 14
stock.  The fund also may invest in certain international bonds if
the portfolio manager believes they have a greater potential for
capital appreciation than equities.  

Capital Resource Fund
Objective: capital appreciation.  Invests primarily in U.S. common
stocks listed on national securities exchanges and other securities
convertible into common stock, diversified over many different
companies in a variety of industries.

Managed Fund
Objective: maximum total investment return.  Invests primarily in
U.S. common stocks listed on national securities exchanges,
securities convertible into common stock, warrants, fixed income 
securities (primarily high-quality corporate bonds) and
money-market instruments.  The fund invests in many different
companies in a variety of industries.

Special Income Fund
Objective: to provide a high level of current income while
conserving the value of the investment for the longest time period. 
Invests primarily in high-quality, lower-risk corporate bonds
issued by many different companies in a variety of industries, and
in government bonds. 

Moneyshare Fund
Objective: maximum current income consistent with liquidity and
conservation of capital.  Invests in high-quality money market
securities with remaining maturities of 13 months or less.  The 
fund also will maintain a dollar-weighted average portfolio
maturity not exceeding 90 days.  The fund attempts to maintain a
constant net asset value of $1 per share.

The Internal Revenue Service (IRS) has issued final regulations
relating to the diversification requirements under section 817(h)
of the Code.  Each mutual fund intends to comply with these
requirements.

The U.S. Treasury and the IRS have indicated they may provide
additional guidance concerning how many variable accounts may be
offered and how many exchanges among variable accounts may be
allowed before the owner is considered to have investment control,
and thus is currently taxed on income earned within variable
account assets.  We do not know at this time what the additional
guidance will be or when action will be taken.  We reserve the
right to modify the contract, as necessary, to ensure that the
owner will not be subject to current taxation as the owner of the
variable account assets.

We intend to comply with all federal tax laws to ensure that the
contract continues to qualify as an annuity for federal income tax
purposes.  We reserve the right to modify the contract as necessary
to comply with any new tax laws.

IDS Life Insurance Company (IDS Life) is the investment adviser for
each of the funds.  IDS Life cannot guarantee that the funds will
meet their investment objectives.  Please read the Retirement
Annuity Mutual Fund prospectus for complete information on 
<PAGE>
PAGE 15
investment risks, deductions, expenses and other facts you should
know before investing.  It is available by contacting IDS Life of
New York at the address or telephone number on the front of this
publication, or from your financial planner.

The fixed account 
   
For the Combination Retirement Annuity contracts only.
    
Purchase payments can also be allocated to the fixed account. The
cash value of the fixed account increases as interest is credited
to the account.  Purchase payments and transfers to the fixed
account become part of the general account of IDS Life of New York,
the company's main portfolio of investments.  Interest is credited
daily and compounded annually.  We may change the interest rates
from time to time.

Because of exemptive and exclusionary provisions, interests in the
fixed account have not been registered under the Securities Act of
1933 (1933 Act), nor is the fixed account registered as an
investment company under the 1940 Act.  Accordingly, neither the
fixed account nor any interests in it are generally subject to the
provisions of the 1933 or 1940 Acts, and we have been advised that
the staff of the SEC has not reviewed the disclosures in this
prospectus that relate to the fixed account.  Disclosures regarding
the fixed account, however, may be subject to certain generally
applicable provisions of the federal securities laws relating to
the accuracy and completeness of statements made in prospectuses.

Buying your annuity

Your financial planner will help you prepare and submit your
application for CRA (VRA is no longer being sold), and send it
along with your initial purchase payment to our Albany office.  As
the owner, you have all rights and may receive all benefits under
the contract.  Annuities cannot be owned in joint tenancy.  

When you apply, you can select:

o  the account(s) in which you want to invest;
o  how you want to make purchase payments;
o  an annual purchase payment amount;
o  the date you want to start receiving annuity payouts (the
   retirement date); and
o  a beneficiary.

If your application is complete, we will process it and apply your
purchase payment to your account(s) within two days after we
receive it.  If your application is accepted, we will send you a 
contract.  If we cannot accept your application within five days,
we will decline it and return your payment.  We will credit
additional purchase payments to your account(s) at the next close
of business.  

Setting the retirement date 
   
Annuity payouts will be scheduled to begin on the retirement date. 
This date can be aligned with your actual retirement from a job, or
it can be a different future date, depending on your needs and 
<PAGE>
PAGE 16
goals and on certain restrictions.  You can also change the date,
provided you send us written instructions at least 30 days before
annuity payouts begin.

For nonqualified annuities, the retirement date must be:
    
o  no earlier than the 60th day after the contract's effective
   date; and 
o  no later than the annuitant's 85th birthday. 

For qualified annuities, to avoid IRS penalty taxes, the retirement
date generally must be:

o  on or after the annuitant reaches age 59 1/2; and
o  by April 1 of the year following the calendar year when the
   annuitant reaches age 70 1/2.

Beneficiary

If death benefits become payable before the retirement date, your
named beneficiary will receive all or part of the contract value. 
If there is no named beneficiary, then you or your estate will be
the beneficiary.  (See "Payment in case of death" for more about
beneficiaries.)

For the Variable Retirement Annuity

This is a single premium contract.  Additional payments cannot be
made.  This annuity is no longer being sold.

For the Combination Retirement Annuity

If installment payments

$50 monthly; $23.08 biweekly

Installments must total $600 in the first year.*

*If you make no purchase payments for 36 months, and your previous
payments total $600 or less, we have the right to give you 30 days'
written notice and pay you the total value of your annuity in a
lump sum.

Maximum payment(s)**
   
Nonqualified:
  first year:  $25,000
  subsequent years:  two times initial gross premium

Qualified:  two times initial gross premium (subject to any IRS
  limits)

**These limits apply in total to all IDS Life of New York annuities
you own.  We reserve the right to increase maximum limits or reduce
age limits.  For qualified annuities the qualified plan's limits on
annual contributions also apply.
    
<PAGE>
PAGE 17
Two ways to make purchase payments

1    By letter

Send your check along with your name and account number to:

Regular mail:

IDS Life Insurance Company of New York
Box 5144
Albany, NY  12205

Express mail:

IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, NY  12203

2    By scheduled payment plan

Your financial planner can help you set up:

o  an automatic payroll deduction, salary reduction, or other group
   billing arrangement; or

o  a bank authorization.

Charges 

Contract administrative charge
This fee is for establishing and maintaining your records.  We
deduct $20 from each VRA contract or $30 from each CRA contract. 
This charge is deducted on each anniversary date from the contract
value at the end of each contract year.

If you surrender your contract, the charge will be deducted at the
time of surrender.  The charge cannot be increased and does not
apply after annuity payouts begin.
   
Mortality and expense risk fee 
This fee is to cover the mortality risk and expense risk and is
applied daily to the variable accounts and reflected in the unit
values of the accounts.  Annually it totals 1% of their average
daily net assets.  Approximately two-thirds of this amount is for
our assumption of mortality risk, and one-third is for our
assumption of expense risk.  This fee does not apply to the fixed
account. 
    
Mortality risk arises because of our guarantee to make annuity
payouts according to the terms of the contract, no matter how long
a specific annuitant lives and no matter how long the entire group
of IDS Life of New York annuitants live.  If, as a group, IDS Life
of New York annuitants outlive the life expectancy we have assumed
in our actuarial tables, then we must take money from our general 
assets to meet our obligations.  If, as a group, IDS Life of New
York annuitants do not live as long as expected, we could profit
from the mortality risk fee.

<PAGE>
PAGE 18
Expense risk arises because the contract administrative charge
cannot be increased and may not cover our expenses.  Any deficit
would have to be made up from our general assets.  We could profit
from the expense risk fee if the annual contract administrative
charge is more than sufficient to meet expenses.

We do not plan to profit from the contract administrative charge. 
However, we do hope to profit from the mortality and expense risk
fee.  We may use any profits realized from this fee for any proper 
corporate purpose, including, among others, payment of distribution
(selling) expenses.  We do not expect that the surrender charge,
discussed in the following paragraphs, will cover sales and
distribution expenses.

Surrender charge
If you surrender part or all of your contract, you may be subject
to a surrender charge as follows:

Variable Retirement Annuity - A surrender charge applies if you
make a surrender in the first seven contract years.

Surrender charge as
    percent of
amount surrendered                       Contract year
        7%                                     1
        6                                      2
        5                                      3
        4                                      4
        3                                      5
        2                                      6
        1                                      7 
        0                                After 7 years

The surrender charge is further limited so it will never exceed
8.5% of aggregate purchase payments made to the contract.  After
the first contract year, you may surrender 10% of your purchase
payment each year without any surrender charge.

Combination Retirement Annuity - A surrender charge applies if you
surrender all or part of your annuity's value in the first 11
contract years.

Surrender charge as
    percent of
amount surrendered                       Contract year
        7%                                    1-5
        6                                      6
        5                                      7
        4                                      8
        3                                      9
        2                                      10
        1                                      11
        0                                After 11 years

The surrender charge is further limited so that it will never
exceed 8.5% of aggregate purchase payments made to the contract.

<PAGE>
PAGE 19
All of the above charges are guaranteed not to increase during the
term of the contract.

Other information on charges:  IDS Financial Corporation (IDS)
makes certain custodial services available to some custodial and
trusteed pension and profit sharing plans and 401(k) plans funded
by IDS Life of New York annuities.  Fees for these services start 
at $30 per calendar year per participant.  A termination fee for
owners under 59 1/2 will be charged (fee waived in case of death or
disability).

Possible group reductions:  In some cases (for example an employer
making the annuity available to employees) lower sales and
administrative expenses may be incurred due to the size of the
group, the average contribution and the use of group enrollment
procedures.  In such cases, we may be able to reduce or eliminate
the contract administrative and surrender charges.  However, we
expect this to occur infrequently.

Valuing your investment

Here is how your annuity accounts are valued:

Fixed account for CRA:  The amounts allocated to the fixed account
are valued directly in dollars and equal the sum of your purchase
payments, plus interest earned, less any amounts surrendered or
transferred.

Variable accounts:  Amounts allocated to the variable accounts are
converted into accumulation units.  Each time you make a purchase
payment or transfer amounts into one of the variable accounts, a
certain number of accumulation units are credited to your contract
for that account.  Conversely, each time you take a partial
surrender, transfer amounts out of a variable account, or are
assessed a contract administrative charge, a certain number of
accumulation units are subtracted from your contract.

The accumulation units are the true measure of investment value in
each account during the accumulation period.  They are related to,
but not the same as, the net asset value of the underlying fund.  

The dollar value of each accumulation unit can rise or fall daily
depending on the performance of the underlying mutual fund and on
certain fund expenses.  Here is how unit values are calculated:

Number of units
To calculate the number of accumulation units for a particular
account, we divide your investment by the current accumulation unit
value.

Accumulation unit value
The current accumulation unit value for each variable account
equals the last value times the account's current net investment
factor.

<PAGE>
PAGE 20
Net investment factor
o  Determined each business day by adding the underlying mutual
   fund's current net asset value per share plus per share amount
   of any current dividend or capital gain distribution; then
o  dividing that sum by the previous net asset value per share; and
o  subtracting the percentage factor representing the mortality and
   expense risk fee from the result.

Because the net asset value of the underlying mutual fund may
fluctuate the accumulation unit value may increase or decrease. 
You bear this investment risk in a variable account.

Factors that affect variable account accumulation units
Accumulation units may change in two ways; in number and in value. 
Here are the factors that influence those changes:

The number of accumulation units you own may fluctuate due to:

o  additional purchase payments allocated to the variable accounts;
o  transfers into or out of the account(s);
o  partial surrenders;
o  surrender charges; and/or
o  contract administrative charges.

Accumulation unit values may fluctuate due to:

o  changes in underlying mutual fund(s) net asset value;
o  dividends distributed to the variable account(s);
o  capital gains or losses of underlying mutual funds;
o  mutual fund operating expenses; and/or
o  mortality and expense risk fees.

Making the most of your annuity
   
Automated dollar-cost averaging
You can use automated transfers to take advantage of dollar-cost
averaging (investing a fixed amount at regular intervals).  For
example, you might have a set amount transferred monthly from a
relatively conservative variable account to a more aggressive one,
or to several others.
    
This systematic approach can help you benefit from fluctuations in
accumulation unit values caused by fluctuations in the market
value(s) of the underlying mutual fund(s).  Since you invest the
same amount each period, you automatically acquire more units when
the market value falls, fewer units when it rises.  The potential
effect is to lower your average cost per unit and increase your
long-term return.  For specific features contact your financial
planner.

<PAGE>
PAGE 21
How dollar-cost averaging works

         Amount      Accumulation    Number of units
Month    invested    unit value      purchased

Jan      $100          $20           5.00  
Feb       100           16           6.25
Mar       100            9          11.11
Apr       100            5          20.00
May       100            7          14.29
June      100           10          10.00
July      100           15           6.67
Aug       100           20           5.00
Sept      100           17           5.88
Oct       100           12           8.33

(footnotes to table) By investing an equal number of dollars each
month...

(arrow in table pointing to April) you automatically buy more units
when the per unit market price is low

(arrow in the table pointing to August) and fewer units when the
per unit market price is high.

You have paid an average price of only $10.81 per unit over the 10
months, while the average market price actually was $13.10.

Dollar-cost averaging does not guarantee that any variable account
will gain in value, nor will it protect against a decline in value
if market prices fall.  However, if you can continue to invest
regularly throughout changing market conditions, it can be an
effective strategy to help meet your long term goals.
   
Transferring money between accounts
You may transfer money from any one account, including the fixed
account, to another before the annuity payouts begin.  If we
receive your request before the close of business, we will process
it that day.  Requests received after the close of business will be
processed the next business day.  There is no charge for transfers. 
Before making a transfer, you should consider the risks involved in
switching investments.
    
We may suspend or modify transfer privileges at any time.  Certain
restrictions apply to transfers involving the fixed account.  (For
information on transfers after annuity payouts begin, see "The
annuity payout period.")

Transfer policies
You may transfer contract values between the variable accounts for
VRA or from the variable account(s) to the fixed account for CRA at
any time.  

<PAGE>
PAGE 22
For the Combination Retirement Annuity

o  If you have made a transfer from the fixed account to the
   variable account(s), you may not make a transfer from any
   variable account back to the fixed account until the next
   contract anniversary.
   
o  You may transfer contract values from the fixed account to the
   variable account(s) once a year during a 31-day transfer period
   starting on each contract anniversary, (except for automated
   transfers, which can be set up for transfer periods of your
   choosing subject to certain minimums.)
    
o  If we receive your transfer request within 30 days before the
   contract anniversary date, the transfer from the fixed account
   to the variable account(s) will be effective on the anniversary.

o  If we receive your request on or within 30 days after the
   contract anniversary date, the transfer from the fixed account
   to the variable account(s) will be effective on the day we
   receive it.

o  We will not accept requests for transfers from the fixed account
   at any other time.

o  No transfers may be made to or from the fixed account once
   annuity payouts begin.

Two ways to request a transfer or surrender

1    By letter

Send your name, account number, Social Security Number or Taxpayer
Identification Number and signed request for a transfer or
surrender to:

Regular mail:
IDS Life Insurance Company of New York
Box 5144
Albany, NY  12205
   
Express mail:
IDS Life Insurance Company of New York
20 Madison Ave. Extension
Albany, NY  12203
    
Minimum amount
Mail transfers:        $250 or entire account balance
Mail surrenders:       none

Maximum amount
Mail transfers:        None (up to contract value)
Mail surrenders:       None (up to contract value)

2    By automated transfers and automated partial surrenders

Your financial planner can help you set up automated transfers
among your accounts or partial surrenders from the accounts.
<PAGE>
PAGE 23
   
You can start or stop this service by written request or other
method acceptable to IDS Life of New York.  You must allow 30 days
for IDS Life of New York to change any instructions that are
currently in place.
    
o  Automated transfers from the fixed to variable account(s) may
   not exceed an amount that, if continued, would deplete the fixed
   account within 12 months.

o  Automated transfers and automated partial surrenders are subject
   to all of the contract provisions and terms, including transfer
   of contract values between accounts.  Automated surrenders may
   be restricted by applicable law under some contracts.

o  You may not make additional purchase payments if automated
   partial surrenders are in effect.

o  Automated partial surrenders may result in IRS taxes and
   penalties on all or part of the amount surrendered.

Minimum amount
Automated transfers or surrenders:  $50 
                                        
Maximum amount
Automated transfers or surrenders:  None (except for automated      
                                    transfers from the fixed        
                                    account)

Surrendering your contract

As owner, you may surrender all or part of your contract at any
time before annuity payouts begin by sending a written request or
calling IDS Life of New York.  For total surrenders we will compute
the value of your contract at the close of business after we
receive your request.  We may ask you to return the contract.  You
may have to pay surrender charges (see "Surrender charge") and IRS
taxes and penalties (see "Taxes").  No surrenders may be made after
annuity payouts begin.

Surrender policies
If you have a balance in more than one account and request a
partial surrender, we will withdraw money from all your accounts in
the same proportion as your value in each account correlates to
your total contract value, unless you request otherwise.

Receiving payment when you request a surrender

By regular or express mail:

o  Payable to owner.

o  Normally mailed to address of record within seven days after
   receiving your request.  However, we may postpone the payment
   if:
    -the surrender amount includes a purchase payment check that
    has not cleared;
    -the NYSE is closed, except for normal holiday and weekend
    closings;
<PAGE>
PAGE 24
    -trading on the NYSE is restricted, according to SEC rules;
    -an emergency, as defined by SEC rules, makes it impractical to
    sell securities or value the net assets of the accounts; or
    -the SEC permits us to delay payment for the protection of
    security holders.
   
TSA special surrender provisions
    
Participants in Tax-Sheltered Annuities:  The Code imposes certain
restrictions on your right as owner to receive early distributions
from a TSA:

o  Distributions attributable to salary reduction contributions
   made after Dec. 31, 1988, plus the earnings on them, or to
   transfers or rollovers of such amounts from other contracts, may
   be made from the TSA only if:
    -you have attained age 59 1/2;
    -you have become disabled as defined in the Code;
    -you have separated from the service of the employer who
    purchased the annuity; or
    -the distribution is made to your beneficiary because of your
    death.

o  If you encounter a financial hardship (within the meaning of the
   Code), you may receive a distribution of all contract values
   attributable to salary reduction contributions made after Dec.
   31, 1988, but not the earnings on them.

o  Even though a distribution may be permitted under the above
   rules, it still may be subject to IRS taxes and penalties.  (See
   "Taxes.")

o  The above restrictions on the right to receive a distribution do
   not affect the availability of the amount credited to the
   contract as of Dec. 31, 1988.  The restrictions do not apply to
   transfers or exchanges of contract value within the annuity, or
   to another registered variable annuity contract or investment
   vehicle available through the employer.
   
o  If the contract has a loan provision, the right to receive a
   loan from your fixed account continues to exist and is described
   in detail in your contract.  You may borrow from the contract
   value allocated to the fixed account.
    
o  For certain types of contributions under a TSA contract to be
   excluded from taxable income, the employer must comply with
   certain nondiscrimination requirements.  You should consult your
   employer to determine whether the nondiscrimination rules apply
   to you.

Changing ownership

You may change ownership of your nonqualified annuity at any time
by filing a change of ownership with us at our Albany office.  The
change will become binding upon us when we receive and record it. 
We take no responsibility for the validity of the change.

<PAGE>
PAGE 25
If you have a nonqualified annuity, you may lose your tax
advantages by transferring, assigning or pledging any part of it. 
(See "Taxes.")

If you have a qualified annuity, you may not sell, assign,
transfer, discount or pledge your contract as collateral for a
loan, or as security for the performance of an obligation or for
any other purpose to any person except IDS Life of New York. 
However, if the owner is a trust or custodian, or an employer
acting in a similar capacity, ownership of a contract may be
transferred to the annuitant.

Benefits in case of death

If you or the annuitant dies (or, for qualified annuities, if the
annuitant dies) before annuity payouts begin, we will pay the
beneficiary as follows:

If death occurs before the annuitant's 75th birthday, the
beneficiary receives the greater of:
o  the contract value; or
o  purchase payments, minus any surrenders.

If death occurs on or after the annuitant's 75th birthday, the
beneficiary receives the contract value.

If your spouse is sole beneficiary under a nonqualified annuity and
you die before the retirement date, your spouse may keep the
annuity as owner.  To do this your spouse must, within 60 days
after we receive proof of death, give us written instructions to
keep the contract in force.

Under a qualified annuity, if the annuitant dies before reaching
age 70 1/2 and before the retirement date, and the spouse is the
only beneficiary, the spouse may keep the annuity in force until
the date on which the annuitant would have reached age 70 1/2.  To
do this, the spouse must give us written instructions within 60
days after we receive proof of death.
   
Payments:  We will pay the beneficiary in a single sum unless you
have given us other written instructions, or the beneficiary may
receive payouts under any annuity payout plan available under this
contract if:
    
o  the beneficiary asks us in writing within 60 days after we
   receive proof of death;
o  payouts begin no later than one year after death; and
o  the payout period does not extend beyond the beneficiary's life
   or life expectancy.

When paying the beneficiary, we will determine the contract's value
at the next close of business after our death claim requirements
are fulfilled.  Interest, if any, will be paid from the date of
death at a rate no less than required by law.  We will mail payment
to the beneficiary within seven days after our death claim
requirements are fulfilled.  (See "Taxes.")

<PAGE>
PAGE 26
The annuity payout period

As owner of the contract, you have the right to decide how and to
whom annuity payouts will be made starting at the retirement date. 
You may select one of the annuity payout plans outlined below, or
we will mutually agree on other payout arrangements.  The amount
available for payouts under the plan you select is the contract
value on your retirement date.  No surrender charges are deducted
under the payout plans listed below.

You also decide whether annuity payouts are to be made on a fixed
or variable basis, or a combination of fixed and variable.  Amounts
of fixed and variable payouts depend on:
o  the annuity payout plan you select;
o  the annuitant's age and, in most cases, sex;
o  the annuity table in the contract;
o  the amounts you allocated to the account(s) at settlement.

In addition, for variable payouts only, amounts depend on the
investment performance of the account(s) you select.  These payouts
will vary from month to month because the performance of the
underlying mutual funds will fluctuate.  (In the case of fixed
annuities, payouts remain the same from month to month.)

Annuity payout plans  
   
You may choose any one of these annuity payout plans by giving us
written instructions at least 30 days before contract values are to
be used to purchase the payout plan:
    
o Plan A - Life annuity - no refund:  Monthly payouts are made
until the annuitant's death.  Payouts end with the last payout
before the annuitant's death; no further payouts will be made. 
This means that if the annuitant dies after only one monthly payout
has been made, no more payouts will be made.
   
o Plan B - Life annuity with five, 10 or 15 years certain: Monthly
payouts are made for a guaranteed payout period of five, 
10 or 15 years that the annuitant elects.  This election will
determine the length of the payout period to the beneficiary if the
annuitant should die before the elected period has expired.  The 
guaranteed payout period is calculated from the retirement date. 
If the annuitant outlives the elected guaranteed payout period,
payouts will continue until the annuitant's death.
    
o Plan C - Life annuity - installment refund:  Monthly payouts are
made until the annuitant's death, with our guarantee that payouts
will continue for some period of time.  Payouts will be made for at
least the number of months determined by dividing the amount
applied under this option by the first monthly payout, whether or
not the annuitant is living.

o Plan D - Joint and last survivor life annuity - no refund:
Monthly payouts are made to the annuitant and a joint annuitant
while both are living.  If either annuitant dies, monthly payouts
continue at the full amount until the death of the surviving
annuitant.  Payouts end with the death of the second annuitant.

<PAGE>
PAGE 27
o Plan E - Payouts for a specified period (available as a fixed
payout only):  Monthly payouts are made for a specific payout
period of 10 to 30 years chosen by the annuitant.  Payouts will be
made only for the number of years specified whether the annuitant
is living or not.  Depending on the time period selected, it is
foreseeable that an annuitant can outlive the payout period
selected.  In addition, a 10% IRS penalty tax could apply under
this payout plan.  (See "Taxes.")

Retrictions for some qualified plans:  If you purchased a qualified
annuity , you must select a payout plan that provides for payouts:

o  over the life of the annuitant;
o  over the joint lives of the annuitant and a designated
   beneficiary;
o  for a period not exceeding the life expectancy of the
   annuitant; or
o  for a period not exceeding the joint life expectancies
   of the annuitant and a designated beneficiary.

If we do not receive instructions:  You must give us written
instructions for the annuity payouts at least 30 days before the
annuitant's retirement date.  If you do not, we will make payouts
under Plan B, with 120 monthly payouts guaranteed.

If monthly payouts would be less than $20:  We will calculate the
amount of monthly payouts at the time the contract value is used to
purchase a payout plan.  If the calculations show that monthly
payouts would be less than $20, we have the right to pay the
contract value to the owner in a lump sum.

Death after annuity payouts begin  
If you or the annuitant die after annuity payouts begin, any amount
payable to the beneficiary will be provided in the annuity payout
plan in effect.
   
Transfers between accounts after annuity payouts begin
After the annuity payouts begin, you may transfer the value of your
annuity from one variable account to another once each contract 
year.  You must send us written instructions to do this.  We will
make the transfer at the next close of business after we receive
your instructions.  
    
Taxes
   
Generally, under current law, any increase in your contract value
is taxable to you only when you receive a payout or surrender. 
(However, see detailed discussion below.)  Any portion of the
annuity payouts and any surrenders you request that represent
ordinary income are normally taxable.  You will receive a 1099 tax
information form for any year in which a taxable distribution was
made.
    
   
Annuity payouts under nonqualified annuities:  A portion of each
payout will be ordinary income and subject to tax, and a portion of
each payout will be considered a return on part of your investment
and will not be taxed.  All amounts received after your investment
in the annuity is fully recovered will be subject to tax.
    <PAGE>
PAGE 28
Tax law requires that all nonqualified deferred annuity contracts
issued by the same company to the same owner during a calendar year
are to be taxed as a single, unified contract when distributions
are taken from any one of such contracts.

Annuity payouts under qualified annuities:  Under a qualified
annuity, the entire payout generally will be includable as ordinary
income and subject to tax except to the extent that contributions
were made with after-tax dollars.  If you or your employer invested
in your contract with pre-tax dollars as part of a qualified
retirement plan, such amounts are not considered to be part of your
investment in the contract and will be taxed when paid to you.
   
Surrenders:  If you surrender part or all of your contract before
your annuity payouts begin, your surrender payment will be taxed to
the extent that the value of your contract immediately before the
surrender exceeds your investment.  You also may have to pay a 10%
IRS penalty for surrenders before reaching age 59 1/2.  For
qualified annuities, other penalties may apply if you surrender
your annuity before your plan specifies that you can receive
payouts.
    
   
Death benefits to beneficiaries:  The death benefit under an
annuity is not tax exempt.  Any amount received by the beneficiary
that represents previously deferred earnings within the contract,
is taxable as ordinary income to the beneficiary in the year(s) he
or she receives the payment(s).
    
Annuities owned by corporations, partnerships or trusts:  Any
annual increase in the value of annuities held by such entities
generally will be treated as ordinary income received during that
year.  This provision is effective for purchase payments made after
Feb. 28, 1986.  However, if the trust was set up for the benefit of
a natural person only, the income will continue to be tax-deferred.

Penalties:  If you receive amounts from your contract before
reaching age 59 1/2, you may have to pay a 10% IRS penalty on the 
amount includable in your ordinary income.  However, this penalty
will not apply to any amount received by you or your beneficiary:
o  because of your death;
o  because you become disabled (as defined in the Code);
o  if the distribution is part of a series of substantially 
   equal periodic payments, made at least annually, over your life
   or life expectancy (or joint lives or life expectancies of you
   and your beneficiary); or
o  if it is allocable to an investment before Aug. 14, 1982 (except
   for qualified annuities).

For a qualified annuity, other penalties or exceptions may apply if
you surrender your annuity before your plan specifies that payouts
can be made.

Withholding, generally:  If you receive all or part of the contract
value from an annuity, withholding may be imposed against the
taxable income portion of the payment.  Any withholding that is
done represents a prepayment of your tax due for the year.  You
take credit for such amounts on the annual tax return that you
file.
<PAGE>
PAGE 29
   
If the payment is part of an annuity payout plan, the amount of
withholding generally is computed using payroll tables.  You can
provide us with a statement of how many exemptions to use in 
calculating the withholding.  As long as you've provided us with a
valid Social Security Number or Taxpayer Identification Number, you
can elect not to have any withholding occur.  
    
If the distribution is any other type of payment (such as a partial
or full surrender) withholding is computed using 10% of the taxable
portion.  Similar to above, as long as you've provided us with a
valid Social Security Number or Taxpayer Identification Number, you
can elect not to have this withholding occur.
   
Some states also impose withholding requirements similar to the
federal withholding described above.  If this should be the case,
any payment from which federal withholding is deducted may also
have state withholding deducted.  The withholding requirements may
differ if payment is being made to a non-U.S. citizen or if the
payment is being delivered outside the United States.
    
   
Withholding from qualified annuities:  If you receive directly all
or part of the contract value from a qualified annuity (except an
IRA), mandatory 20% income tax withholding generally will be
imposed at the time the payout is made.  This mandatory withholding
is in place of the elective withholding discussed above.  This
mandatory withholding will not be imposed if:
o  instead of receiving the distribution check, you elect to have
   the distribution rolled over directly to an IRA or another
   eligible plan;
o  the payout is one in a series of substantially equal periodic
   payouts, made at least annually, over your life or life
   expectancy (or the joint lives or life expectancies of you and
   your designated beneficiary) or over a specified period of 10
   years or more; or
o  the payment is a minimum distribution required under the Code.
    
   
Payments made to a surviving spouse instead of being directly
rolled over to an IRA may also be subject to mandatory 20% income
tax withholding.
    
State withholding also may be imposed on taxable distributions.
   
Transfer of ownership of a nonqualified annuity:  If you make such
a transfer without receiving adequate consideration, the transfer
is considered a gift, and also may be considered a surrender for
federal income tax purposes.  If the gift is a currently taxable
event, the amount of the earnings at the time of the transfer will
be taxed to the original owner, who also may be subject to a 10%
IRS penalty as discussed earlier.  In this case, the new owner's
investment in the annuity will be the value of the annuity at the
time of the transfer.
    
Collateral assignment of a nonqualified annuity:  If you
collaterally assign or pledge your contract earnings on purchase
payments you made on or after Aug. 13, 1982 will be taxed to you
like a surrender.
<PAGE>
PAGE 30
Important:  Our discussion of federal tax laws is based upon our
understanding of these laws as they are currently interpreted. 
Federal tax laws or current interpretations of them may change.  

For this reason and because tax consequences are complex and highly
individual and cannot always be anticipated, you should consult a
tax adviser if you have any questions about taxation of your
contract.
   
Tax Qualification

The contract is intended to qualify as an annuity for Federal
income tax purposes.  To that end, the provisions of the contract
are to be interpreted to ensure or maintain such tax qualification,
notwithstanding any other provisions of the contract.  We reserve
the right to amend the contract to reflect any clarifications that
may be needed or are appropriate to maintain such qualification or
to conform the contract to any applicable changes in the tax
qualification requirements.  We will send you a copy of any such
amendment.
    
Voting rights

As a contract owner with investments in the variable account(s),
you may vote on important mutual fund policies until annuity
payouts begin.  Once they begin, the person receiving them has
voting rights.  We will vote fund shares according to the
instructions of the person with voting rights.

Before annuity payouts begin, the number of votes you have is
determined by applying your percentage interest in each variable
account to the total number of votes allowed to the account.
   
After annuity payouts begin, the number of votes you have is equal
to:
    
o  the reserve held in each account for your contract, divided by
o  the net asset value of one share of the applicable underlying
   mutual fund.

As we make annuity payouts, the reserve for the contract decreases;
therefore, the number of votes also will decrease.

We calculate votes separately for each account not more than 60
days before a shareholders' meeting.  Notice of these meetings,
proxy materials and a statement of the number of votes to which the
voter is entitled, will be sent.

We will vote shares for which we have not received instructions in
the same proportion as the votes for which we have received 
instructions.  We also will vote the shares for which we have 
voting rights in the same proportion as the votes for which we have
received instructions.

<PAGE>
PAGE 31
About IDS Life of New York

The Variable Retirement Annuity and the Combination Retirement
Annuity are issued by IDS Life of New York.  IDS Life of New York
is a wholly owned subsidiary of IDS Life which itself is a wholly
owned subsidiary of IDS.  IDS is a wholly owned subsidiary of the
American Express Company (American Express).  American Express is a
financial services company principally engaged through subsidiaries
(in addition to IDS) in travel related services, investment
services and international banking services.

IDS Life of New York is a stock life insurance company organized in
1972 under the laws of the State of New York.  Our home office is
at 20 Madison Avenue Extension, Albany, New York.  Our address for
mail is P.O. Box 5144, Albany, NY 12205.  IDS Life of New York is
licensed in New York and North Dakota and we conduct a conventional
life insurance business in the state of New York.

IDS Financial Services Inc. is the principal underwriter for the
accounts.  Its home office is IDS Tower 10, Minneapolis, MN 55440-
0010.  IDS Financial Services Inc. is a wholly owned subsidiary of
IDS.

The IDS family of companies offers not only insurance and
annuities, but also mutual funds, investment certificates and a
broad range of financial management services.

As a subsidiary of IDS, IDS Life of New York is part of a 100-year
tradition of excellent service and responsible financial
management.
   
IDS Financial Services, Inc. serves individuals and businesses
through its nationwide network of more than 175 offices and more
than 7600 planners.
    
Other subsidiaries provide investment management and related
services for pension, profit-sharing, employee savings and
endowment funds of businesses and institutions.

Regular and special reports

Services

To help you track and evaluate the performance of your annuity, IDS
Life of New York provides:

Quarterly statements showing the value of your investment.

Annual reports containing required information on the annuity and
its underlying investments.

A personalized annuity progress report detailing the cumulative
return since the contract was purchased and the average annual rate
of return on your investments.  This report, which is unique in the
industry, is available upon request from your financial planner.
<PAGE>
PAGE 32
Table of contents of the Statement of Additional Information
   
Performance information....................... 3
Calculating annuity payouts................... 5
Rating agencies............................... 7
Principal underwriter......................... 8
Independent auditors.......................... 8
Prospectus.................................... 8
Financial statements -
     IDS Life of New York Accounts 4, 5, 6, 9, 10 and 11........ 9
     IDS Life Insurance Company of New York..................... 17
    
___________________________________________________________________
Please check the appropriate box to receive a copy of the Statement
of Additional Information for:

_____ IDS Life of New York Variable Retirement and Combination
      Retirement Annuities

_____ IDS Life Retirement Annuity Mutual Funds

Please return this request to:

IDS Life of New York Annuity Service
IDS Life Insurance Company of New York
P.O. Box 5144
Albany, NY  12205

Your name _______________________________________________________

Address _________________________________________________________

City ______________________  State ______________ Zip ___________
<PAGE>
PAGE 33
















                STATEMENT OF ADDITIONAL INFORMATION

                                for

     VARIABLE RETIREMENT AND COMBINATION RETIREMENT ANNUITIES

        IDS LIFE OF NEW YORK ACCOUNTS 4, 5, 6, 9, 10 AND 11

                          April 29, 1994


IDS Life of New York Accounts 4, 5, 6, 9, 10 and 11 are separate
accounts established and maintained by IDS Life Insurance Company
of New York (IDS Life of New York).

This Statement of Additional Information, dated April 29, 1994, is
not a prospectus.  It should be read together with the Accounts'
prospectus, dated April 29, 1994, which may be obtained from your
IDS personal financial planner, or by writing or calling IDS Life
of New York Annuity Service at the address or telephone number
below.

IDS Life of New York Annuity Service
20 Madison Avenue Extension
Albany, NY 12203
(518) 869-8613
<PAGE>
PAGE 34
                         TABLE OF CONTENTS
   
Performance Information.......................................p. 3 

Calculating Annuity Payouts...................................p. 5

Rating Agencies...............................................p. 7

Principal Underwriter.........................................p. 8 

Independent Auditors..........................................p. 8
 
Prospectus....................................................p. 8 

Financial Statements 
          - IDS Life of New York Accounts 4, 5, 6, 9, 10 
            and 11............................................p. 9 
          - IDS Life Insurance Company of New York............p.17 
    
<PAGE>
PAGE 35
PERFORMANCE INFORMATION

Calculation of yield for Account 6

IDS Life of New York Account 6, which invests in IDS Life
Moneyshare Fund, Inc., calculates an annualized simple yield and a
compound yield based on a seven-day period.

The simple yield is calculated by determining the net change in the
value of a hypothetical account having the balance of one
accumulation unit at the beginning of the seven-day period.  (The
net change does not include capital change, but does include a pro
rata share of the annual contract charges, including the annual
contract administrative charge and the mortality and expense risk
fee.)  The net change in the account value is divided by the value
of the account at the beginning of the period to obtain the return
for the period.  That return is then multiplied by 365/7 to obtain
an annualized figure.  The value of the hypothetical account
includes the amount of any declared dividends, the value of any
shares purchased with any dividend paid during the period and any
dividends declared for such shares.  The variable account's
(account) yield does not include any realized or unrealized gains
or losses, nor does it include the effect of any applicable
surrender charge.

The account calculates its compound yield according to the
following formula:

                                                  365/7
Compound Yield = [(return for seven-day period +1)     ] - 1
   
On Dec. 31, 1993, the account's annualized yield was 1.88% and its
compound yield was 1.90%.  
    
The rate of return, or yield, on the account's accumulation unit
may fluctuate daily and does not provide a basis for determining
future yields.  Investors must consider, when comparing an
investment in Account 6 with fixed annuities, that fixed annuities
often provide an agreed-to or guaranteed fixed yield for a stated
period of time, whereas the variable account's yield fluctuates. 
In comparing the yield of Account 6 to a money market fund, you
should consider the different services that the annuity provides.

Calculation of yield for non-money market accounts

For an account other than the money market account, quotations of
yield will be based on all investment income earned during a
particular 30-day period, less expenses accrued during the period
(net investment income) and will be computed by dividing net
investment income per accumulation unit by the value of an
accumulation unit on the last day of the period, according to the
following formula:

                         YIELD = 2[(a-b + 1)6 - 1]
                                     cd
<PAGE>
PAGE 36
where:    a = dividends and investment income earned during the
              period.
          b = expenses accrued for the period (net of
              reimbursements).
          c = the average daily number of accumulation units
              outstanding during the period that were entitled to
              receive dividends.
          d = the maximum offering price per accumulation unit on
              the last day of the period.

Yield on the account is earned from the increase in the net asset
value of shares of the fund in which the account invests and from
dividends declared and paid by the fund, which are automatically
invested in shares of the fund.

Calculation of average annual total return 

Quotations of average annual total return for an account will be
expressed in terms of the average annual compounded rate of return
of a hypothetical investment in the annuity contract over a period
of one, five and 10 years (or, if less, up to the life of the
account), calculated according to the following formula:

                         P(1+T) n = ERV

where:       P = a hypothetical initial payment of $1,000.
             T = average annual total return.
             n = number of years.
           ERV = Ending Redeemable Value of a hypothetical $1,000
                 payment made at the beginning of the one, five,
                 or ten year (or other) period at the end of the
                 one, five, or ten year (or other) period (or
                 fractional portion thereof).
   
Account total return figures reflect the deduction of the contract
administrative charge and mortality and expense risk fee. 
Performance figures will be shown with the deduction of the
applicable surrender charge; in addition, performance figures may
be shown without the deduction of a surrender charge.  The
Securities and Exchange Commission requires that an assumption be
made that the contract owner surrenders the entire contract at the
end of the one, five and ten year periods (or, if less, up to the
life of the account) for which performance is required to be
calculated.
    
Aggregate total return

Aggregate total return represents the cumulative change in the net
asset value of shares of the fund in which the account invests over
a specified period of time and is computed by the following
formula:

                               ERV - P
                                  P
<PAGE>
PAGE 37
where:       P = a hypothetical initial payment of $1,000.
           ERV = Ending Redeemable Value of a hypothetical
                 $1,000 payment made at the beginning of the one,
                 five, or ten year (or other) period at the end of
                 the one, five, or ten year (or other) period (or
                 fractional portion thereof).

Performance of the accounts may be quoted or compared to rankings,
yields, or returns as published or prepared by independent rating
or statistical services or publishers or publications such as The
Bank Rate Monitor National Index, Barron's, Business Week,
Donoghue's Money Market Fund Report, Financial Services Week,
Financial Times, Financial World, Forbes, Fortune, Global Investor,
Institutional Investor, Investor's Daily, Kiplinger's Personal
Finance, Lipper Analytical Services, Money, Mutual Fund Forecaster,
Newsweek, The New York Times, Personal Investor, Stanger Report,
Sylvia Porter's Personal Finance, USA Today, U.S. News and World
Report, The Wall Street Journal and Wiesenberger Investment
Companies Service. 

CALCULATING ANNUITY PAYOUTS

The Variable Account

The following calculations are done separately for each of the
variable accounts.  The separate monthly payouts, added together,
make up your total variable annuity payout.

Initial Payout:  To compute your first monthly payment, we:
o  determine the dollar value of your annuity as of the valuation
date seven days before the retirement date.

o  apply the result to the annuity table contained in the contract
or another table at least as favorable.  The annuity table shows
the amount of the first monthly payment for each $1,000 of value
which depends on factors built into the table, as described below.

Annuity Units:  The value of your account is then converted to
annuity units.  To compute the number credited to you, we divide
the first monthly payment by the annuity unit value (see below) on
the valuation date on (or next day preceding) the seventh calendar
day before the retirement date.  The number of units in your
account is fixed.  The value of the units fluctuate with the
performance of the underlying mutual fund.

Subsequent Payouts:  To compute later payouts, we multiply:
o  the annuity unit value on the valuation date on or immediately
preceding the seventh calendar day before the payout is due; by
o  the fixed number of annuity units credited to you.

<PAGE>
PAGE 38
Annuity Table:  The table shows the amount of the first monthly
payment for each $1,000 of contract value according to the age and,
when applicable, the sex of the annuitant.  (Where required by law,
we will use a unisex table of settlement rates.)  The table assumes
that the contract value is invested at the beginning of the annuity
payout period and earns a 3.5% rate of return, which is reinvested
and helps to support future payouts.

Annuity Unit Values:  This value was originally set at $1 for each
variable account.  To calculate later values we multiply the last
annuity value by the product of:
o  the net investment factor; and
o  the neutralizing factor.  The purpose of the neutralizing factor
is to offset the effect of the assumed investment rate built into
the annuity table.  With an assumed investment rate of 3.5%, the
neutralizing factor is 0.999906 for a one day valuation period.

Net Investment Factor:
o  Determined each business day by adding the underlying mutual
fund's current net asset value per share plus per share amount of
any current dividend or capital gain distribution; then
o  dividing that sum by the previous net asset value per share; and
o  subtracting the percentage factor representing the mortality and
expense risk fee from the result.

Because the net asset value of the underlying mutual fund may
fluctuate, the net investment factor may be greater or less than
one, and the accumulation unit value may increase or decrease.  You
bear this investment risk in a variable account.

The Fixed Account

Your fixed annuity payout amounts are guaranteed.  Once calculated,
your payout will remain the same and never change.  To calculate
your annuity payouts we:
   
o  take the value of your fixed account at the retirement date or
the date you have selected to begin receiving your annuity payouts;
then
o  using an annuity table we apply the value according to the
annuity payout plan you select; and
o  the annuity payout table we use will be the one in effect at the
time you choose to begin your annuity payouts.  The table will be
equal to or greater than the table in your contract.
    
<PAGE>
PAGE 39
RATING AGENCIES
   
The following chart provides information on ratings* given to IDS
Life of New York by independent rating agencies that evaluate the
financial soundness of insurance companies.
    
Rating Agency     Rating             Relevance of Rating
  A.M. Best         A+           Reflects A.M. Best's opinion
                (Superior)       regarding IDS Life of New York's
                                 strong distribution network,
                                 favorable overall balance sheet
                                 profile, consistently improving
                                 profitability, adequate level of
                                 capitalization and asset liability
                                 management expertise.

  Duff & Phelps    AAA           Reflects Duff & Phelps' opinion
                                 regarding IDS Life of New York's
                                 consistently excellent
                                 profitability record, stable
                                 operating leverage, leadership
                                 position in chosen markets and
                                 effective use of asset/liability
                                 management techniques.

  Moody's          Aa2           Reflects Moody's opinion regarding
                                 IDS Life of New York's leadership
                                 position in financial planning,
                                 strong asset/liability management
                                 and good capitalization.  IDS Life
                                 of New York has a strong market
                                 focus and it greatly emphasizes
                                 quality service.

A.M. Best rates over 1,600 insurance companies on a 15 level scale
with letters ranging from A++ to F to "NA" ratings based on a
company's financial strength and claims paying ability.  

Duff & Phelps rates over 125 companies for claims-paying ability
with 19 rating categories from AAA to CCC-.

Moody's rates over 80 companies for financial strength with 19
rating categories ranging from Aaa to C.

*  Ratings relate to IDS Life of New York's ability to fulfill its
obligations under its contracts and not to the management or
performance of the separate accounts.
       
<PAGE>
PAGE 40
PRINCIPAL UNDERWRITER

The principal underwriter for the accounts is IDS Financial
Services Inc. which offers the variable annuities on a continuous
basis.
   
Surrender charges received by IDS Life of New York for 1993, 1992
and 1991, aggregated $151,536, $136,471 and $117,959, respectively. 
Commissions paid by IDS Life of New York for 1993, 1992 and 1991,
aggregated $1,244,668, $631,691 and $220,527, respectively.  The
surrender charges were applied toward payment of commissions.
    
INDEPENDENT AUDITORS

The Financial Statements of the Accounts and of IDS Life of New
York appearing in this Statement of Additional Information have
been audited by Ernst & Young, independent auditors, 1400 Pillsbury
Center, Minneapolis, MN  55402, to the extent indicated in their
reports.  Ernst & Young are experts in accounting and auditing.

PROSPECTUS

The prospectus dated April 29, 1994, is hereby incorporated in this
Statement of Additional Information by reference.
<PAGE>
PAGE 41
   
Annual Financial Information

Report of Independent Auditors
The Board of Directors IDS Life Insurance Company of New York 

We have audited the accompanying individual and combined statements
of net assets of IDS Life of New York Accounts 4, 10, 11, 5, 6 and
9 as of December 31, 1993, and the related statements of operations
for the year then ended, and the statements of changes in net
assets for each of the two years in the period then ended except
for IDS Life of New York Accounts 10 and 11 which are for the
period January 13, 1992 (commencement of operations) to December
31, 1993.  These financial statements are the responsibility of the
management of IDS Life Insurance Company of New York.  Our
responsibility is to express an opinion on these financial
statements based on our audits.

We conducted our audits in accordance with generally accepted
auditing standards.  Those standards require that we plan and
perform the audit to obtain reasonable assurance about whether the
financial statements are free of material misstatement.  An audit
includes examining, on a test basis, evidence supporting the
amounts and disclosures in the financial statements.  Our
procedures included confirmation by the underlying affiliated
mutual funds of securities owned at December 31, 1993.  An audit
also includes assessing the accounting principles used and
significant estimates made by management, as well as evaluating the
overall financial statement presentation.  We believe that our
audits provide a reasonable basis for our opinion.

In our opinion, the financial statements referred to above present
fairly, in all material respects, the individual and combined
financial position of IDS Life of New York Accounts 4, 10, 11, 5, 6
and 9 at December 31, 1993, and the individual and combined results
of their operations and changes in their net assets for the periods
described in the first paragraph, in conformity with generally
accepted accounting principles.     



ERNST & YOUNG 
Minneapolis, Minnnesota 
March 18, 1994
<PAGE>
PAGE 42
<TABLE>
<CAPTION>
Statements of Net Assets                                                                                             Dec.31, 1993 
                                                                                                                       Combined
                                                                Segregated Asset Account                              Retirement
Assets                       4                10              11              5                6             9         Annuity     
<S>                     <C>             <C>            <C>             <C>              <C>           <C>             <C>
Investments in shares of mutual funds at market value:
IDS Life Capital 
Resource Fund -- 4,058,544 
shares at net asset value 
of $25.43 per share 
(cost $91,865,516)..... $103,189,604    $        --    $        --     $        --      $       --    $         --    $103,189,604
IDS Life International 
Equity Fund -- 2,215,912 
shares at net asset value 
of $12.57 per share 
(cost $24,690,415).....           --     27,861,387             --              --              --              --      27,861,387
IDS Life Aggressive Growth 
Fund -- 1,915,556 shares at 
net asset value of $12.29 
per share 
(cost $20,651,203).....           --             --     23,560,379              --              --              --      23,560,379
IDS Life Special 
Income Fund, Inc. -- 5,943,867 
shares at net asset value of 
$11.99 per share 
(cost $66,955,406).....           --             --             --      71,252,709              --              --      71,252,709
IDS Life Moneyshare 
Fund, Inc. -- 7,633,034 
shares at net asset 
value of $1.00 per share 
(cost $7,632,422)......           --             --             --              --       7,632,437              --       7,632,437
IDS Life Managed 
Fund, Inc. -- 7,747,645 
shares at net asset value 
of $14.46 per share 
(cost $101,101,906)....           --             --             --              --              --     112,051,097     112,051,097
                         103,189,604     27,861,387     23,560,379      71,252,709       7,632,437     112,051,097     345,547,613
Dividends receivable...           --             --             --         401,362          17,877              --         419,239
Accounts receivable from 
IDS Life of New York for 
contract purchase 
payments...............       80,303         76,537         50,980         160,662          44,939          88,263         501,684
Receivable from mutual funds 
for share redemptions..       23,301             --             --           4,481           4,500           4,215          36,497
Total assets...........  103,293,208     27,937,924     23,611,359      71,819,214       7,699,753     112,143,575     346,505,033
Liabilities                                                                                                                       
Payable to IDS Life of New York for:  
Mortality and expense 
risk fee...............       86,694         22,135         19,098          59,772           6,575          93,031         287,305
Contract terminations..       23,301             --             --           4,481           4,500           4,215          36,497
Payable to mutual funds 
for investments 
purchased..............       80,303         76,537         50,980         502,252          56,241          88,263         854,576
Total liabilities......      190,298         98,672         70,078         566,505          67,316         185,509       1,178,378
Net assets applicable to 
contracts in accumulation 
period.................  103,102,910     27,839,252     23,541,281      71,252,709       7,632,437     111,927,848     345,296,437
Net assets applicable to 
contracts in payment 
period.................           --             --             --              --              --          30,218          30,218
Total net assets....... $103,102,910    $27,839,252    $23,541,281     $71,252,709      $7,632,437    $111,958,066    $345,326,655
Accumulation units 
outstanding............   30,089,286     21,650,329     19,430,140      23,259,461       4,113,215      50,761,194                
Net asset value per 
accumulation unit...... $       3.43    $      1.29    $      1.21     $      3.06      $     1.86    $       2.21                

See accompanying notes to financial statements.
</TABLE>
<PAGE>
PAGE 43
<TABLE>
<CAPTION>
Statements of Operations                                                                                  Year ended Dec. 31, 1993
                                                                                                                          Combined
                                                              Segregated Asset Account                                  Retirement
Investment Income              4              10             11             5                6              9              Annuity
<S>                       <C>            <C>            <C>             <C>             <C>             <C>            <C>
Dividend income from 
mutual funds..........    $5,184,348     $  400,110     $   24,937      $4,167,435      $  221,780      $5,309,806     $15,308,416
Mortality and expense 
risk fee (Note 3).....       856,743        115,511        137,678         585,189          84,561         871,280       2,650,962
Investment income 
(loss) -- net.........     4,327,605        284,599       (112,741)      3,582,246         137,219       4,438,526      12,657,454
Realized and Unrealized Gain (Loss) on Investments -- net                                                                         
Realized gain on sales of investments in mutual funds:  
Proceeds from sales...       763,607         40,954        120,075       1,819,157       6,118,533         430,750       9,293,076
Cost of investments 
sold..................       688,066         38,903        105,604       1,718,546       6,118,488         383,113       9,052,720
Net realized gain on 
investments...........        75,541          2,051         14,471         100,611              45          47,637         240,356
Net change in unrealized 
appreciation or depreciation 
of investments........    (1,140,664)     3,187,166      2,213,814       3,853,558             (78)      4,505,085      12,618,881
Net gain (loss) on
investments...........    (1,065,123)     3,189,217      2,228,285       3,954,169             (33)      4,552,722      12,859,237
Net increase from 
operations............    $3,262,482     $3,473,816     $2,115,544      $7,536,415      $  137,186      $8,991,248     $25,516,691

See accompanying notes to financial statements. 
</TABLE>
<PAGE>
PAGE 44
<TABLE>
<CAPTION>
Statements of Changes in Net Assets                                                                        Year ended Dec. 31, 1993
                                                                                                                           Combined
                                                        Segregated Asset Account                                         Retirement
Operations                    4               10             11              5                6              9            Annuity  
<S>                     <C>             <C>            <C>             <C>              <C>           <C>             <C>
Investment income 
(loss) -- net........   $  4,327,605    $   284,599    $  (112,741)    $ 3,582,246      $  137,219    $  4,438,526    $ 12,657,454
Net realized gain 
on investments.......         75,541          2,051         14,471         100,611              45          47,637         240,356
Net change in unrealized 
appreciation or depreciation 
of investments.......     (1,140,664)     3,187,166      2,213,814       3,853,558             (78)      4,505,085      12,618,881 
Net increase from 
operations...........      3,262,482      3,473,816      2,115,544       7,536,415         137,186       8,991,248      25,516,691 
Contract Transactions                                                                                                              
Variable annuity contract 
purchase payments....     18,777,760     10,515,795      7,709,492      24,943,613       3,300,265      27,275,648      92,522,573
Net transfers*.......     10,974,972     10,637,026      7,453,651      (4,049,476)     (5,062,298)     14,441,715      34,395,590
Loan repayments......         48,485          4,310          8,666          15,852             748          55,004         133,065
Annuity payments.....             --             --             --              --              --          (1,334)         (1,334)
Contract charges 
(Note 3).............       (128,063)       (14,509)       (22,540)        (63,354)         (8,774)       (112,688)       (349,928)
Contract terminations:
Surrender benefits...     (2,192,846)      (116,744)      (151,998)     (1,502,646)       (520,490)     (1,580,413)     (6,065,137)
Death benefits.......       (180,194)        (7,620)       (25,236)       (258,347)        (47,363)       (210,689)       (729,449)
Increase (decrease) 
from contract 
transactions.........     27,300,114     21,018,258     14,972,035      19,085,642      (2,337,912)     39,867,243     119,905,380 
Net assets at beginning 
of year..............     72,540,314      3,347,178      6,453,702      44,630,652       9,833,163      63,099,575     199,904,584 
Net assets at end 
of year..............   $103,102,910    $27,839,252    $23,541,281     $71,252,709      $7,632,437    $111,958,066    $345,326,655 
Accumulation Unit Activity                                                                                                         
Units outstanding at 
beginning of year....     21,677,434      3,420,979      5,961,128      16,709,514       5,377,745      31,827,907
Contract purchase 
payments.............      5,794,766      9,087,531      6,947,859       8,512,405       1,781,518      12,981,467
Net transfers*.......      3,377,950      9,261,875      6,691,285      (1,340,234)     (2,735,160)      6,843,248
Transfers for policy 
loans................         15,002          3,648          7,699           5,322             403          25,991
Contract charges.....        (40,290)       (12,864)       (20,597)        (22,070)         (5,187)        (54,437)
Contract terminations:
Surrender benefits...       (679,422)      (104,338)      (134,780)       (517,677)       (280,629)       (761,379)
Death benefits.......        (56,154)        (6,502)       (22,454)        (87,799)        (25,475)       (101,603)                
Units outstanding at 
end of year..........     30,089,286     21,650,329     19,430,140      23,259,461       4,113,215      50,761,194                 
*Includes transfer activity from (to) other Accounts and transfers (from) to IDS Life of New York for conversion from (to) Fixed
Account.

See accompanying notes to financial statements.
</TABLE>
<PAGE>
PAGE 45
<TABLE>
<CAPTION>
Statements of Changes in Net Assets                                                                       Year ended Dec. 31, 1992
                                                                                                                          Combined
                                                             Segregated Asset Account                                   Retirement 
Operations                  4               10**            11**           5                6             9                Annuity 
<S>                      <C>             <C>            <C>            <C>             <C>             <C>            <C>
Investment income 
(loss) -- net........    $ 2,197,656     $   16,901     $  (21,189)    $ 2,603,202     $   263,321     $ 3,189,741    $  8,249,632
Net realized gain 
(loss) on 
investments..........        641,906           (620)        (4,938)         18,476              78         161,230         816,132
Net change in 
unrealized appreciation 
or depreciation 
of investments.......        110,221        (16,194)       695,362         323,191             (82)        322,221       1,434,719 
Net increase from 
operations...........      2,949,783             87        669,235       2,944,869         263,317       3,673,192      10,500,483 
Contract Transactions                                                                                                              
Variable annuity contract 
purchase payments....     16,762,060      1,779,395      3,386,175      14,264,106       5,713,670      14,804,432      56,709,838
Net transfers*.......     10,473,175      1,593,457      2,432,942      (1,400,075)     (8,847,718)      8,507,346      12,759,127
Loan repayments......         27,958             48             58          11,593          32,888          15,130          87,675
Contract charges 
(Note 3).............        (97,821)        (2,268)        (5,657)        (50,047)        (12,284)        (75,557)       (243,634)
Contract terminations:
Surrender benefits...     (1,573,252)       (22,829)       (28,460)     (1,139,726)       (176,888)     (1,043,874)     (3,985,029)
Death benefits.......       (142,002)          (712)          (591)       (132,615)       (130,352)       (220,887)       (627,159)
Increase (decrease) 
from contract 
transactions.........     25,450,118      3,347,091      5,784,467      11,553,236      (3,420,684)     21,986,590      64,700,818 
Net assets at beginning 
of period............     44,140,413             --             --      30,132,547      12,990,530      37,439,793     124,703,283 
Net assets at end 
of period............    $72,540,314     $3,347,178     $6,453,702     $44,630,652     $ 9,833,163     $63,099,575    $199,904,584 
Accumulation Unit Activity                                                                                                         
Units outstanding at 
beginning of period..     13,590,889             --             --      12,227,888       7,253,291      20,104,683
Contract purchase 
payments.............      5,351,531      1,836,583      3,481,370       5,560,505       3,203,920       7,923,981
Net transfers*.......      3,316,424      1,626,791      2,519,974        (567,994)     (4,899,331)      4,520,856
Transfers for policy 
loans................          8,965             49             59           4,499          18,227           8,014
Contract charges.....        (31,834)        (2,373)        (5,945)        (19,940)         (7,224)        (41,427)
Contract terminations:
Surrender benefits...       (509,433)       (39,314)       (33,756)       (442,195)       (119,334)       (565,958)
Death benefits.......        (49,108)          (757)          (574)        (53,249)        (71,804)       (122,242)                
Units outstanding at end 
of period............     21,677,434      3,420,979      5,961,128      16,709,514       5,377,745      31,827,907                 
*   Includes transfer activity from (to) other Accounts and transfers (from) to IDS Life for conversion from (to) Fixed Account.
**   For the period from Jan. 13, 1992 (commencement of operations) to Dec. 31, 1992.

See accompanying notes to financial statements.
</TABLE>
<PAGE>
PAGE 46
Notes to Financial Statements     

___________________________________________________________________
1.  Organization

IDS Life of New York Accounts 4, 5, 6 and 9 (the Accounts) were
established as segregated asset accounts of IDS Life Insurance
Company of New York (IDS Life of New York) under New York law and
are registered collectively as a single unit investment trust under
the Investment Company Act of 1940.  Accounts 4, 5 and 6 were
established on Nov. 12, 1981.  Account 9 was established on Feb.
12, 1986 and commenced operations on April 30, 1986.  Accounts 10
and 11 were established on Oct. 8, 1991 and commenced operations on
Jan. 13, 1992.

The assets of each Account are held for the exclusive benefit of
the Retirement Annuity contract owners and are not chargeable with
liabilities arising out of the business conducted by any other
Account or by IDS Life of New York.  Contract owners allocate their
variable purchase payments to one or more of the six segregated
asset accounts.  Such funds are then invested in shares of six
mutual funds organized by IDS Life Insurance Company (IDS Life) as
the investment vehicles for variable annuity contracts issued by
IDS Life of New York and by IDS Life.  All of the mutual funds, 
except IDS Life Managed Fund, Inc., commenced operations Oct. 13,
1981.  IDS Life Managed Fund, Inc. commenced operations on April
30, 1986.  These mutual funds are registered under the Investment
Company Act of 1940 as diversified, open-end management investment
companies.  Funds allocated to IDS Life of New York Account 4 are
invested in the shares of IDS Life Capital Resource Fund; IDS Life
of New York Account 5 invests in the shares of IDS Life Special
Income Fund, Inc.; IDS Life of New York Account 6 invests in the
shares of IDS Life Moneyshare Fund, Inc.; IDS Life of New York
Account 9 invests in the shares of IDS Life Managed Fund, Inc.; IDS
Life of New York Account 11 invests in IDS Life Aggressive Growth
Fund; and IDS Life of New York Account 10 invests in IDS Life
International Equity Fund.

IDS Life, parent company of IDS Life of New York, serves as
manager, investment adviser and underwriter for the underlying six
mutual funds.  IDS Financial Services Inc., an affiliated company,
is the principal underwriter for the Accounts.  IDS Life of New
York serves as issuer for the Accounts.
                                                                   
___________________________________________________________________
2.  Summary of Significant Accounting Policies

Investments in Mutual Funds Investments in shares of the mutual
funds are stated at market value, which is the net asset value per
share as determined by the respective mutual funds.

Investment transactions are accounted for on the date the shares
are purchased and sold.  The cost of investments sold and redeemed
is determined on the average cost method.  Dividend distributions 
<PAGE>
PAGE 47
2.  Summary of Significant Accounting Policies (continued)

received from the mutual funds are reinvested, net of any expenses
payable to IDS Life of New York, in additional shares of the mutual
funds and are recorded as income by the Accounts on the ex-dividend
date.  Unrealized appreciation or depreciation of investments in
the accompanying financial statements represents the Accounts'
share of the mutual funds' undistributed net investment income,
undistributed realized gain or loss and the unrealized appreciation
or depreciation on their investment securities. Federal Income
Taxes IDS Life of New York is taxed as a life insurance company. 
The Accounts are treated as part of IDS Life of New York for
federal income tax purposes.  Under existing tax law, no income
taxes are payable with respect to any income of the Accounts.

___________________________________________________________________
3.  Mortality and Expense Risk Fee and Administrative Charges

IDS Life of New York makes contractual assurances to the Accounts
that possible future adverse changes in contract expenses and
mortality experience of the annuitants and beneficiaries will not
affect the Accounts.  The mortality and expense risk fee paid to
IDS Life of New York is computed daily and is equal, on an annual
basis, to 1 percent of the average daily net assets of the
Accounts.

An annual charge of $20 is deducted from the contract value of each
Variable Retirement Annuity contract.  An annual charge of $30 is
deducted from the contract value of each Combination Retirement
Annuity contract.  A quarterly charge of $6 is deducted from the
contract value of each Flexible Annuity contract.  The annual
charges are deducted at contract year end and the quarterly charges
are deducted at contract quarter end, during the accumulation
period, for administrative services provided to the Accounts by IDS
Life of New York.  A contingent deferred sales charge (surrender
charge) will be imposed upon:

a) certain Variable Retirement Annuity contract surrenders during
   the first seven years,

b) Combination Retirement Annuity contract surrenders during the
   first eleven years and

c) Flexible Annuity contract surrenders of amounts other than those
   representing earnings or those representing purchase payments
   more than six years old.

Charges by IDS Life of New York for surrenders are not available on
an individual segregated asset account basis.  Charges for all
segregated asset accounts amounted to $151,536 in 1993 and $136,470
in 1992.  Such charges are not an expense of the Accounts.  They
are deducted from contract surrender benefits paid by IDS Life of
New York.
<PAGE>
PAGE 48
___________________________________________________________________
4.  Investment Transactions

The Accounts' purchases of mutual fund shares (net of charges),
including reinvestment of dividend distributions, were as follows:
<TABLE>
<CAPTION>

                                                         Year Ended Dec. 31,   
Account   Investment                                    1993            1992   
  <C>     <C>                                      <C>              <C>
   4      IDS Life Capital Resource Fund........   $ 32,417,890     $31,752,733
  10      IDS Life International Equity Fund....     21,363,338       3,559,082
  11      IDS Life Aggressive Growth Fund.......     14,993,546       5,983,220
   5      IDS Life Special Income Fund, Inc.....     24,487,045      17,077,200
   6      IDS Life Moneyshare Fund, Inc.........      3,917,840       5,188,593
   9      IDS Life Managed Fund, Inc............     44,777,396      26,743,798
                                                   $141,957,055     $90,304,626
</TABLE>
<PAGE>
PAGE 49
Report of Independent Auditors

The Board of Directors
IDS Life Insurance Company of New York
         
We have audited the accompanying balance sheets of IDS Life
Insurance Company of New York (a wholly owned subsidiary of IDS
Life Insurance Company) as of December 31, 1993 and 1992, and the
related statements of income and cash flows for each of the three
years in the period ended December 31, 1993.  These financial
statements are the responsibility of the Company's management.  Our
responsibility is to express an opinion on these financial
statements based on our audits.

We conducted our audits in accordance with generally accepted
auditing standards.  Those standards require that we plan and
perform the audit to obtain reasonable assurance about whether the
financial statements are free of material misstatement.  An audit
includes examining, on a test basis, evidence supporting the
amounts and disclosures in the financial statements.  An audit also
includes assessing the accounting principles used and significant
estimates made by management, as well as evaluating the overall
financial statement presentation.  We believe that our audits
provide a reasonable basis for our opinion. 

In our opinion, the financial statements referred to above present
fairly, in all material respects, the financial position of IDS
Life Insurance Company of New York at December 31, 1993 and 1992,
and the results of its operations and its cash flows for each of
the three years in the period ended December 31, 1993, in
conformity with generally accepted accounting principles. 



Ernst & Young
February 3, 1994
Minneapolis, Minnesota  
 <PAGE>
PAGE 50
IDS Life of New York Financial Information
___________________________________________________________________
The financial statements shown below are those of the insurance
company and not those of the Fund, the Account. They are included
in the prospectus for the purpose of informing investors as to the
financial condition of the insurance company and its ability to
carry out its obligations under the variable annuity contracts.
<TABLE>
<CAPTION>

IDS Life Insurance Company of New York
______________________________________________________________________________________________________________________________
Balance Sheet                                                                                Dec. 31, 1993       Dec. 31, 1992

Assets                                                                                                 (Thousands)
______________________________________________________________________________________________________________________________
<S>                                                                                            <C>                  <C>
Investments:
Fixed maturities (Fair value: 1993, $1,240,593; 1992, $1,172,029)                              $1,171,023           $1,127,809
Mortgage loans on real estate (Fair value: 1993, $124,030; 1992, $64,693)                         123,337               62,008
Policy loans                                                                                       12,952               10,845
Other investments                                                                                   2,239                2,895
______________________________________________________________________________________________________________________________
Total investments                                                                               1,309,551            1,203,557
______________________________________________________________________________________________________________________________
Cash and cash equivalents                                                                               -                3,248
Accrued investment income                                                                          21,342               19,866
Deferred policy acquisition costs                                                                  87,891               77,269
Other assets                                                                                        2,270                1,446
Assets held in segregated asset accounts, primarily common stocks at market                       380,796              214,593
______________________________________________________________________________________________________________________________
Total assets                                                                                   $1,801,850           $1,519,979
______________________________________________________________________________________________________________________________
Liabilities and Stockholder's Equity
______________________________________________________________________________________________________________________________
Liabilities:
Fixed annuities - future policy benefits                                                       $1,059,005           $  966,645
Universal life-type insurance - future policy benefits                                            120,917              114,286
Traditional life, disability income and long-term care insurance - future policy benefits          40,045               40,984
Policy claims and other policyholders' funds                                                        2,347                2,065
Deferred federal income taxes                                                                      13,018               13,480
Amounts due to brokers                                                                              4,952               15,400
Other liabilities                                                                                  20,311               15,963
Liabilities related to segregated asset accounts                                                  380,796              214,593
______________________________________________________________________________________________________________________________
Total liabilities                                                                               1,641,391            1,383,416
______________________________________________________________________________________________________________________________
Stockholder's equity:
Capital stock, $10 par value per share; 200,000 shares authorized, issued and outstanding           2,000                2,000
Additional paid-in capital                                                                         49,000               49,000
Net unrealized appreciation on equity securities                                                       24                   12
Retained earnings                                                                                 109,435               85,551
______________________________________________________________________________________________________________________________
Total stockholder's equity                                                                        160,459              136,563
______________________________________________________________________________________________________________________________
Total liabilities and stockholder's equity                                                     $1,801,850           $1,519,979
Commitments and contingencies (Note 7)
______________________________________________________________________________________________________________________________

See accompanying notes to financial statements.
</TABLE>
<PAGE>
PAGE 51
<TABLE>
<CAPTION>
______________________________________________________________________________________________________________________________
Statements of Income                                                                                 Years ended Dec. 31,
                                                                                                 1993        1992       1991 
                                                                                                          (Thousands)
______________________________________________________________________________________________________________________________
<S>                                                                                         <C>         <C>          <C>
Revenues:
Traditional life, disability income and long-term care insurance premiums                   $   7,110   $   6,282    $   5,289
Policyholder and contractholder charges                                                         9,634       8,359        7,356
Mortality and expense risk fees                                                                 2,904       1,696        1,081
Net investment income                                                                         110,147     102,071       94,630
Net gain (loss) on investments                                                                  1,334       2,478       (3,598)
______________________________________________________________________________________________________________________________
Total revenues                                                                                131,129     120,886      104,758
______________________________________________________________________________________________________________________________
Benefits and expenses:
Death and other benefits - traditional life, disability income and
long-term care insurance                                                                        5,715       5,705        7,359
Death and other benefits - universal life-type insurance
and investment contracts                                                                        2,465       2,133        2,058
Decrease in liabilities for future policy benefits for traditional
life, disability income and long-term care insurance                                           (1,343)       (855)      (2,494)
Interest credited on universal life-type insurance and investment contracts                    68,987      68,487       65,232
Amortization of deferred policy acquisition costs                                              10,434       8,137        6,919
Other insurance and operating expenses                                                          7,652       6,403        4,919
______________________________________________________________________________________________________________________________
Total benefits and expenses                                                                    93,910      90,010       83,993
______________________________________________________________________________________________________________________________
Income before income taxes                                                                     37,219      30,876       20,765
______________________________________________________________________________________________________________________________
Income taxes                                                                                   13,335      10,914        6,908
______________________________________________________________________________________________________________________________
Net income                                                                                  $  23,884   $  19,962    $  13,857
______________________________________________________________________________________________________________________________

See accompanying notes to financial statements.
</TABLE>
<PAGE>
PAGE 52
<TABLE>
<CAPTION>
______________________________________________________________________________________________________________________________
Statements of Cash Flows                                                                             Years ended Dec. 31,
                                                                                                 1993        1992       1991
                                                                                                          (Thousands)
______________________________________________________________________________________________________________________________
<S>                                                                                         <C>         <C>          <C>
Cash flows from operating activities:
Net income                                                                                  $  23,884   $  19,962    $  13,857
Adjustments to reconcile net income to net cash provided by operating activities:
Issuance - policy loans, excluding universal life-type insurance                               (1,044)       (635)        (290)
Repayment - policy loans, excluding universal life-type insurance                                 455         327          200
Change in accrued investment income                                                            (1,476)     (1,797)        (812)
Change in deferred policy acquisition costs, net                                              (10,622)    (10,974)      (8,487)
Change in liabilities for future policy benefits for traditional life, disability
income and long-term care insurance                                                              (939)       (855)      (2,494)
Change in policy claims and other policyholders' funds                                            282         592          (92)
Change in deferred federal income taxes                                                          (449)      1,302         (749)
Change in other liabilities                                                                     4,348         466         (276)
Accretion of discount, net                                                                     (1,598)     (1,410)        (954)
Net (gain) loss on investments                                                                 (1,334)     (2,478)       3,598
Premiums related to universal life-type insurance                                              15,141      13,919       14,978
Surrenders and death benefits related to universal life-type insurance                         (9,785)     (5,976)      (5,920)
Interest credited to account balances related to universal life-type insurance                  6,892       7,168        7,021
Policyholder and contractholder charges, non-cash                                              (5,663)     (5,452)      (5,129)
Other, net                                                                                       (780)        700       (1,051)
______________________________________________________________________________________________________________________________
Net cash provided by operating activities                                                   $  17,312   $  14,859    $  13,400
______________________________________________________________________________________________________________________________
Cash flows from investing activities:
Acquisition of investments, excluding policy loans                                          $(397,102)  $(440,037)   $(247,841)
Maturities, sinking fund payments and calls of investments, excluding policy loans            264,994     210,179       60,250
Sale of investments, excluding policy loans                                                    31,152      68,537       84,794
Change in amounts due to brokers                                                              (10,448)     12,249       (1,193)
______________________________________________________________________________________________________________________________
Net cash used in investing activities                                                        (111,404)   (149,072)    (103,990)
______________________________________________________________________________________________________________________________
Cash flows from financing activities:
Considerations received related to investment contracts                                       149,269     159,913      111,553
Surrenders and death benefits related to investment contracts                                (119,158)    (80,632)     (75,878)
Interest credited to account balances related to investment contracts                          62,250      61,319       58,211
Issuance - universal life-type insurance policy loans                                          (3,403)     (3,668)      (3,061)
Repayment - universal life-type insurance policy loans                                          1,886       1,548        1,663
Cash dividend to parent                                                                             -      (6,000)           -
______________________________________________________________________________________________________________________________
Net cash provided by financing activities                                                      90,844     132,480       92,488
______________________________________________________________________________________________________________________________
Net increase (decrease) in cash and cash equivalents                                           (3,248)     (1,733)       1,898
Cash and cash equivalents at beginning of year                                                  3,248       4,981        3,083
______________________________________________________________________________________________________________________________
Cash and cash equivalents at end of year                                                    $       -   $   3,248    $   4,981
______________________________________________________________________________________________________________________________

See accompanying notes to financial statements. 
</TABLE>
<PAGE>
PAGE 53
Notes to Financial Statements ($ Thousands)
Dec. 31, 1993, 1992 and 1991

1. Summary of significant accounting policies

Nature of business
IDS Life Insurance Company of New York (the Company) is engaged in
the insurance and annuity business in the state of New York and
sells various forms of fixed and variable individual life
insurance, individual disability income and long-term care
insurance, and single and installment premium fixed and variable
annuities.

Basis of presentation
The Company is a wholly owned subsidiary of IDS Life Insurance
Company (IDS Life), which is a wholly owned subsidiary of IDS
Financial Corporation (IDS), which is a wholly owned subsidiary of
American Express Company.  The accompanying financial statements
have been prepared in conformity with generally accepted accounting
principles which vary in certain respects from reporting practices
prescribed or permitted by state insurance regulatory authority.
Also, the accompanying financial statements are presented on a
historical cost basis without adjustment of the net assets
attributable to the 1984 acquisition of IDS by American Express
Company. 

Investments
Investments in fixed maturities are carried at cost, adjusted where
appropriate for amortization of premiums and accretion of
discounts.  Mortgage loans on real estate are carried principally
at the unpaid principal balances of the related loans.  Policy
loans are carried at the aggregate of the unpaid loan balances
which do not exceed the cash surrender values of the related
policies.  Other investments include interest rate caps and equity
securities.  When evidence indicates a decline, which is other than
temporary, in the underlying value or earning power of individual
investments, such investments are written down to the estimated
realizable value by a charge to income.  Equity securities are
carried at market value and the related net unrealized appreciation
or depreciation is reported as a credit or charge to stockholder's
equity.

The Company has the ability and the intent to recover the costs of
these investments by holding them for the forseeable future.  The
ability to hold investments to scheduled maturity dates is
dependent on, among other things, annuity contract owners
maintaining their annuity contracts in force.

The Company will implement, effective January 1, 1994, Statement of
Financial Accounting Standards No. 115, "Accounting for Certain
Investments in Debt and Equity Securities."  Under the new rules,
debt securities that the Company has both the positive intent and
ability to hold to maturity will be carried at amortized cost. 
Debt securities that the Company does not have the positive intent
and ability to hold to maturity and all marketable equity  
<PAGE>
PAGE 54
1. Summary of significant accounting policies (continued)

securities will be classified as available-for-sale and carried at
fair value.  Unrealized gains and losses on securites classified as
available-for-sale will be carried as a separate component of
stockholder's equity.  The effect of the new rules will be to
increase stockholder's equity by approximately $12 million, net of
taxes, as of January 1, 1994, but the new rules will have no
material impact on the Company's results of operations.

Realized investment gain or loss is determined on an identified
cost basis.
      
Interest rate cap contracts are purchased to reduce the Company's
exposure to rising interest rates which would increase the cost of
future policy benefits for interest sensitive products.  Costs are
amortized over the lives of the agreements and benefits are
recognized when realized.

Prepayments are anticipated on certain investments in
mortgage-backed securities in determining the constant effective
yield used to recognize interest income.  Prepayment estimates are
based on information received from brokers who deal in
mortgage-backed securities.
 
Statement of cash flows
The Company considers investments with a maturity at the date of
their acquisition of three months or less to be cash equivalents. 
These securities are carried principally at amortized cost which
approximates fair value.

Supplementary information to the statement of cash flows for the
years ended Dec. 31 is summarized as follows:

                                          1993      1992      1991 
Cash paid during the year for:
Income taxes                            $14,138    $9,193    $7,093
Interest on borrowings                      235       132        41

Recognition of profits on annuity contracts and insurance policies
The Company issues single premium deferred annuity contracts that
provide for a service fee (surrender charge) at annually decreasing
rates upon withdrawal of the annuity accumulation value by the
contract owner.  No sales fee is deducted from the contract
considerations received on these contracts ("no load" annuities). 
Single premium deferred annuities issued prior to 1980 had a sales
fee and no surrender charge.  All of the Company's single premium
deferred annuity contracts provide for crediting the contract
owners' accumulations at specified rates of interest.  Such rates
are revised by the Company from time to time based on changes in
the market investment yield rates for fixed-income securities.
<PAGE>
PAGE 55
1. Summary of significant accounting policies (continued)

Profits on single premium deferred annuities and installment
annuities are recognized by the Company over the lives of the
contracts and represent the excess of investment income earned
from investment of contract considerations over interest credited
to contract owners and other expenses.

The retrospective deposit method is used in accounting for
universal life-type insurance.  This method recognizes profits over
the lives of the policies in proportion to the estimated gross
profits expected to be realized.

Premiums on traditional life, disability income and long-term care
insurance policies are recognized as revenue when collected or due,
and related benefits and expenses are associated with premium
revenue in a manner that results in recognition of profits over the
lives of the insurance policies.  This association is accomplished
by means of the provision for future policy benefits and the
deferral and subsequent amortization of policy acquisition costs.

Deferred policy acquisition costs
The costs of acquiring new business, principally sales
compensation, policy issue costs, underwriting and certain sales
expenses, have been deferred on insurance and annuity contracts.
The deferred acquisition costs for single premium deferred
annuities and installment annuities are amortized based upon
surrender charge revenue and a portion of the excess of investment
income earned from investment of the contract considerations over
the interest credited to contract owners.  The costs for universal
life-type insurance are amortized over the lives of the policies as
a percentage of the estimated gross profits expected to be realized
on the policies.  For traditional life, disability income and
long-term care insurance policies, the costs are amortized over an
appropriate period in proportion to premium revenue. 

Liabilities for future policy benefits
Liabilities for universal life-type insurance, single premium
deferred annuities and installment annuities are  accumulation
values.

Liabilities for fixed annuities in a benefit status are based on
the Progressive Annuity Table with interest at 5 percent, the 1971
Individual Annuity Table with interest at 7 percent or 8.25
percent, or the 1983a Table with various interest rates ranging
from 5.5 percent to 9.5 percent, depending on year of issue.

Liabilities for future benefits on traditional life insurance have
been computed principally by the net level premium method, based on
anticipated rates of mortality (approximating the 1965-1970 Select
and Ultimate Basic Table for policies issued after 1980 and the
1955-1960 Select and Ultimate Basic Table for policies issued prior
to 1981), policy persistency derived from IDS Life's experience
data (first-year rates ranging from approximately 70 percent to 90
percent and increasing rates thereafter), and estimated future 
<PAGE>
PAGE 56
1. Summary of significant accounting policies (continued)

investment yields of 4 percent for policies issued before 1974 and
5.25 percent for policies issued from 1974 to 1980.  Cash value
plans issued in 1980 and later assume future investment rates that
grade from 9.5 percent to 5 percent over 20 years.  Term insurance
issued from 1981 to 1984 assumes an 8 percent level investment
rate, and term insurance issued after 1984 assumes investment rates
that grade from 10 percent to 6 percent over 20 years.

Liabilities for future disability income policy benefits have been
computed principally by the net level premium method, based on the
1964 Commissioners Disability Table with the 1958 Commissioners
Standard Ordinary Mortality Table at 3 percent interest for 1980
and prior, 8 percent interest for persons disabled from 1981 to
1991 and 6 percent interest for persons disabled after 1991.

Liabilities for future benefits on long-term care insurance have
been computed principally by the net level premium method, using
morbidity rates based on the 1985 National Nursing Home Survey and
mortality rates based on the 1983a Table.  The interest rate basis
is 9.5 percent grading to 7 percent over ten years for policies
issued from 1989 to 1992, 7.75 percent grading to 7 percent over
four years for policies issued after 1992, 8 percent for claims
incurred in 1989 to 1991 and 6 percent for claims incurred after
1991.

At Dec. 31, 1993 and 1992, the carrying amount and fair value of
fixed annuities future policy benefits, after excluding life
insurance-related contracts carried at $54,911 and $50,316, were
$1,004,095 and $916,329, and $970,169 and $884,021, respectively. 
The fair value is net of policy loans of $1,085 and $488 at Dec.
31, 1993 and  1992, respectively.  The fair value of these benefits
is based on the status of the annuities at Dec. 31, 1993 and 1992. 
The fair value of deferred annuities is estimated as the carrying
amount less any surrender charges and related loans.  The fair
value for annuities in non-life contingent payout status is
estimated as the present value of projected benefit payments at the
rate appropriate for contracts issued in 1993 and 1992,
respectively. 

Reinsurance
The maximum amount of life insurance risk retained by the Company
on any one life is $750 of life and waiver of premium benefits plus
$50 of accidental death benefits.  The maximum amount of disability
income risk retained by the Company on any one life is $6 of
monthly benefit for benefit periods longer than three years.  The
excesses are reinsured with other life insurance companies on a
yearly renewable term basis.

In 1993 the Company adopted Statement of Financial Accounting
Standard (SFAS) No. 113, "Accounting and Reporting for Reinsurance
of Short-Duration and Long-Duration Contracts."  Under SFAS No.
113, amounts paid or deemed to have been paid for reinsurance
contracts are recorded as reinsurance receivables.  These amounts 
<PAGE>
PAGE 57
1. Summary of significant accounting policies (continued)

have been included in other assets on the balance sheet.  Prior to
1993, these amounts were recorded as a reduction of the liability
for future insurance policy benefits.  The cost of reinsurance is
accounted for over the period covered by the reinsurance contract.

Federal income taxes
The Company's taxable income is included in the consolidated
federal income tax return of American Express Company.  The Company
provides for income taxes on a separate return basis, except that,
under an agreement between IDS and American Express Company, tax
benefit is recognized for losses to the extent they can be used on
the consolidated tax return.  It is the policy of IDS and its
subsidiaries that IDS will reimburse a subsidiary for any tax
benefit.
      
Included in other liabilities at Dec. 31, 1993 and 1992 are $3,462
and $3,083, respectively, payable to IDS Life for federal income
taxes.
      
Segregated asset account business
The segregated asset account assets and liabilities represent funds
held for the exclusive benefit of the variable annuity and variable
life insurance contract owners.  The Company receives a monthly
cost of insurance charge and receives a minimum death benefit
guarantee fee from variable life insurance segregated asset
accounts and a  mortality and expense assurance fee from the
variable annuity and variable life insurance segregated asset
accounts.
      
The Company makes contractual mortality assurances to the variable
annuity contract owners that the net assets of the segregated asset
accounts will not be affected by future variations in the actual
life expectancy experience of the annuitants and the beneficiaries
from the mortality assumptions implicit in the annuity contracts. 
The Company makes periodic fund transfers to, or withdrawals from,
the segregated asset accounts for such actuarial adjustments for
variable annuities that are in the benefit payment period.  The
Company guarantees, for the variable life insurance policyholders,
the cost of the contractual insurance rate and that the death
benefit will never be less than the death benefit at the date of
issuance.
                
At Dec. 31, 1993 and 1992 the fair value of liabilities related to
segregated asset accounts was $339,122 and $190,300, respectively.
The fair value of these liabilities is estimated as the carrying
amount less variable insurance contracts carried at $23,620 and
$14,010, respectively,  and surrender charges, if applicable. 
      
Reclassification
Certain 1992 and 1991 amounts have been reclassified to conform to
the 1993 presentation.
                                       
<PAGE>
PAGE 58
2. Investments

Market values of investments in fixed maturities represent quoted
market prices and estimated fair values when quoted prices are not
available.  Estimated fair values are determined by established
procedures involving, among other things, review of market indices,
price levels of current offerings of comparable issues, price
estimates and market data from independent brokers and financial
files.
      
Changes in net unrealized appreciation (depreciation) of fixed
maturities for the years ended Dec. 31, 1993, 1992 and 1991 were
$25,350, $(10,980) and $60,200, respectively.

Net gain (loss) on investments for the years ended Dec. 31 is
summarized as follows:

                                         1993      1992       1991 
Fixed maturities                       $1,809    $  173    $  (694)
Other investments                         (37)       26          - 
                                        1,772       199       (694)
Net decrease (increase)
in allowance for losses                  (438)    2,279     (2,904)
                                       $1,334    $2,478    $(3,598)

Fair values of and gross unrealized gains and losses on investments
in fixed maturities carried at amortized cost at Dec. 31 are as
follows:
<TABLE>
<CAPTION>
      
                                                           Gross          Gross   
                                           Amortized     Unrealized     Unrealized     Fair
1993                                         Cost          Gains          Losses       Value 
<S>                                     <C>               <C>          <C>         <C>
U.S. Government agency obligations      $      400        $    40      $     -     $      440
State and municipal obligations                105             15            -            120
Corporate bonds and obligations            747,474         60,482        3,510        804,446
Mortgage-backed securities                 424,696         15,265        4,374        435,587
                                         1,172,675         75,802        7,884      1,240,593
Less allowance for losses                    1,652              -        1,652              -
                                        $1,171,023        $75,802      $ 6,232     $1,240,593

                                                           Gross          Gross   
                                           Amortized     Unrealized     Unrealized     Fair   
1992                                         Cost          Gains          Losses       Value 
U.S. Government agency obligations      $      417        $    10      $     4     $      423    
State and municipal obligations                276              7            -            283
Corporate bonds and obligations            634,225         33,634        7,526        660,333
Mortgage-backed securities                 494,050         19,500        2,560        510,990
                                         1,128,968         53,151       10,090      1,172,029
Less allowance for losses                    1,159              -        1,159              -
                                        $1,127,809        $53,151      $ 8,931     $1,172,029
</TABLE>
<PAGE>
PAGE 59
2. Investments (continued)

The amortized cost and fair value of investments in fixed
maturities at Dec. 31, 1993 by contractual maturity are shown
below.  Expected maturities will differ from contractual
maturities because borrowers may have the right to call or prepay
obligations with or without call or prepayment penalties.

                                        Amortized         Fair  
                                          Cost            Value    
Due in one year or less              $    7,915          $    8,069
Due from one to five years              124,638             134,461
Due from five to ten years              411,729             444,134
Due in more than ten years              203,697             218,342
Mortgage-backed securities              424,696             435,587
                                     $1,172,675          $1,240,593

Proceeds from sales of investments in fixed maturities  during 1993
and 1992 were $26,710 and $67,133, respectively.  During 1993 and
1992, gross gains of $4,022 and $6,251, respectively, and gross
losses of $2,213 and $6,078, respectively, were realized on those
sales.
      
At Dec. 31, 1993, gross and net unrealized appreciation on equity
securities amounted to $18.  At Dec. 31, 1992 the amount of net
unrealized appreciation on equity securities included $19 of gross
unrealized appreciation, $1 of gross unrealized depreciation and
deferred taxes of $6.  The fair value of equity securities was $190
and $184 at Dec. 31, 1993 and 1992, respectively.

Included in other investments at Dec. 31, 1993 are interest rate
caps at amortized cost of $2,050 with a fair value of $385.  These
interest rate caps carry a notional amount of $200,000 and expire
on various dates in 1996 and 1997.
      
At Dec. 31, 1993, bonds carried at $266 were on deposit with the
state of New York as required by law.
      
Net investment income for the years ended Dec. 31 is summarized as
follows:
<TABLE>
<CAPTION>

                                         1993         1992        1991 
<S>                                    <C>          <C>         <C>
Interest on fixed maturities           $100,940     $ 96,452    $90,935
Interest on mortgage loans                8,424        4,908      3,124
Other investment income                   1,220          841        538
Interest on cash equivalents                 63          378        389
                                        110,647      102,579     94,986
Less investment expenses                    500          508        356
                                       $110,147     $102,071    $94,630
</TABLE>
         
At Dec. 31, 1993, investments in fixed maturities comprised 89
percent of the Company's total invested assets.  Securities are
rated by Moody's and Standard & Poor's (S&P) except for 
<PAGE>
PAGE 60
2. Investments (continued)

approximately $154 million which is rated by IDS internal analysts
using criteria similar to Moody's and S&P.  A summary of
investments in fixed maturities by rating on Dec. 31 is as follows:

                                             Dec. 31,     Dec. 31,
Rating                                         1993         1992   
Aaa/AAA                                    $  425,404    $  492,098
Aa/AA                                          13,285        16,003
Aa/A                                           14,213        11,634
A/A                                           139,878       128,084
A/BBB                                          62,817        38,572
Baa/BBB                                       343,233       314,047
Baa/BB                                         55,812        39,444
Below investment grade                        118,033        89,086
                                           $1,172,675    $1,128,968

At Dec. 31, 1993, 99 percent of the securities rated Aaa/AAA are
GNMA, FNMA and FHLMC mortgage-backed securities.  No holdings of
any other issuer are greater than 1.4 percent of the Company's
total investments in fixed maturities. 
       
At Dec. 31, 1993, approximately 9.4 percent of the Company's
invested assets were mortgage loans on real estate.  Summaries of
mortgage loans by region and by type of real estate are as follows:
<TABLE>
<CAPTION>

                                      Dec. 31, 1993                  Dec. 31, 1992
                               On Balance     Commitments     On Balance     Commitments
Region                            Sheet       to Purchase        Sheet       to Purchase
<S>                            <C>             <C>            <C>                <C>
West North Central             $ 27,349        $ 1,713        $25,305            $     -
East North Central               28,349          2,569         13,525              4,510
South Atlantic                   26,423          8,279         10,669              5,261
Middle Atlantic                  15,912          8,564          4,709              8,018
Pacific                          12,224              -          4,527              3,508
Mountain                          6,723          4,568          2,588              1,002
New England                       4,858          2,855          1,185              1,754
East South Central                1,646              -              -              1,002
West South Central                  298              -              -                  -
                                123,782         28,548         62,508             25,055
Less allowance for losses           445              -            500                  -
                               $123,337        $28,548        $62,008            $25,055

<PAGE>
PAGE 61
2. Investments (continued)

                                      Dec. 31, 1993                  Dec. 31, 1992
                               On Balance     Commitments     On Balance     Commitments
Property type                     Sheet       to Purchase        Sheet       to Purchase
Apartments                     $ 47,178        $15,130        $18,710            $12,778
Department/retail stores         38,253          9,706         22,613              9,020
Office buildings                 11,475          1,142          8,219              1,002
Industrial buildings             13,781          1,142          7,510              2,255
Medical buildings                 5,229          1,428          3,256                  -
Nursing/retirement                5,507              -              -                  -
Other                             2,061              -          2,081                  -
Hotels/motels                       298              -              -                  -
Residential                           -              -            119                  -
                                123,782         28,548         62,508             25,055
Less allowance for losses           445              -            500                  -
                               $123,337        $28,548        $62,008            $25,055
</TABLE>

Mortgage loan fundings are restricted by state insurance regulatory
authority to 80 percent or less of the market value of the real
estate at the time of origination of the loan.  The Company holds
the mortgage document, which gives the right to take possession of
the property if the borrower fails to perform according to the
terms of the agreement.  The fair value of the mortgage loans is
determined by a discounted cash flow analysis using mortgage
interest rates currently offered for mortgages of similar
maturities.  Commitments to purchase mortgages are made in the
ordinary course of business.  The fair value of the mortgage
commitments is $nil.

3. Income taxes

The Company qualifies as a life insurance company for federal
income tax purposes.  As such, the Company is subject to the
Internal Revenue Code provisions applicable to life insurance
companies.
      
Income tax expense consists of the following:

                                          1993      1992     1991  
Federal income taxes:
Current                                 $13,164   $ 9,037   $7,165
Deferred                                   (449)    1,302     (749)
                                         12,715    10,339    6,416
State income taxes-Current                  620       575      492 
Income tax expense                      $13,335   $10,914   $6,908 

<PAGE>
PAGE 62
3. Income taxes (continued)

Increases (decreases) to the federal tax provision applicable to
pretax income based on the statutory rate are attributable to:
<TABLE>
<CAPTION>
      
                                                     1993                  1992                 1991      
                                              Provision    Rate     Provision    Rate    Provision    Rate
<S>                                            <C>         <C>       <C>         <C>      <C>        <C>
Federal income taxes based
on the statutory rate                          $13,026     35.0%     $10,498     34.0%    $7,060     34.0%
Increases (decreases) are attributable to:
Tax-excluded interest and dividend income         (557)    (1.5)        (429)    (1.4)      (452)    (2.2)
Other, net                                         246      0.7          270      0.9       (192)    (0.9)
Federal income taxes                           $12,715     34.2%     $10,339     33.5%    $6,416     30.9%
</TABLE>
                                   
A portion of life insurance company income earned prior to 1984 was
not subject to current taxation but was accumulated, for tax
purposes, in a "policyholders' surplus account."  At Dec. 31, 1993,
the Company had a policyholders' surplus account balance of $798. 
The policyholders' surplus account is only taxable if dividends to
the stockholder exceed the stockholder's surplus account or if the
Company is liquidated.  Deferred income taxes of $279 have not been
established because no distributions of such amounts are
contemplated.

Significant components of the Company's deferred tax assets and
liabilities as of Dec. 31 are as follows:

                                                  1993         1992
Deferred tax assets:                   
Policy reserves                                $ 15,683    $ 12,088
Other                                             1,543         893
Total deferred tax assets                        17,226      12,981
Deferred tax liabilities:
Deferred policy acquisition costs                27,250      24,102
Investments                                       2,994       2,359
Total deferred tax liabilities                   30,244      26,461
Net deferred tax liabilities                   $ 13,018    $ 13,480

4. Stockholder's equity

Retained earnings available for distribution as dividends to parent
are limited to the Company's surplus as determined in accordance
with accounting practices prescribed by state insurance regulatory
authority.  Statutory unassigned surplus aggregated $52,642 as of
Dec. 31, 1993 and $26,468 as of Dec. 31, 1992 (see Note 3 with
respect to the income tax effect of certain distributions).  In
addition, any dividend distributions in 1994 in excess of
approximately $5,264 would require approval of the New York
Insurance Department.         

Dividends paid to parent were $nil in 1993, $6,000 in 1992 and $nil
in 1991.
      
The Company is required to maintain a minimum statutory  capital
and surplus of $3,000.

<PAGE>
PAGE 63
5. Retirement plan and services

The Company participates in the retirement plan of IDS which covers
all permanent employees age 21 and over who have met certain
employment requirements.  The benefits are based on the number of
years the employee participates in the plan, their final average
monthly salary, the level of social security benefits the employee
is eligible for and the level of vesting the employee has earned in
the plan.  IDS' policy is to fund retirement plan costs accrued
subject to ERISA and federal income tax considerations.
      
The Company's share of the total net periodic pension cost was $nil
in 1993, 1992 and 1991.

The Company has a "Sales Benefit Plan" which is an unfunded,
noncontributory retirement plan for all eligible financial
planners.  Total plan costs for 1993, 1992 and 1991, which are
calculated on the basis of commission earnings of the individual
financial planners, were $1,042, $1,164 and $757, respectively. 
Such costs are included in deferred policy acquisition costs.

The Company also participates in defined contribution pension plans
of IDS which cover all employees who have met certain employment
requirements.  Company contributions to the plans are a percent of
either each employee's eligible compensation or basic
contributions.  Costs of these plans charged to operations in 1993,
1992 and 1991 were $201, $144 and $146, respectively.
      
The Company participates in defined benefit health care plans of
IDS that provide health care and life insurance benefits to retired
employees and retired financial planners.  The plans include
participant contributions and service-related eligibility
requirements.  Upon retirement, such employees are considered to
have been employees of IDS.  IDS expenses these benefits and
allocates the expenses to its subsidiaries.  Accordingly, costs of
such benefits to the Company are included in employee compensation
and benefits and cannot be identified on a separate company basis.
      
Certain commission and marketing services expenses are allocated to
the Company by its affiliates.  The expenses for 1993, 1992 and
1991 were $5,338, $4,967 and $3,914, respectively.  Certain of the
costs assessed to the Company are included in deferred policy
acquisition costs.

6. Incentive plans and operating expenses

The Company maintains a "Persistency Payment Plan."  Under  the
terms of this plan, financial planners earn additional compensation
based on the volume and persistency of insurance sales.  The total
costs for the plan for 1993, 1992 and 1991 were $1,387, $1,252 and
$963, respectively.  Such costs are included in deferred policy
acquisition costs.
      
Charges by IDS Life and IDS for the use of joint facilities and
other services aggregated $7,421, $6,914 and $5,954 for 1993, 1992
and 1991, respectively.  Certain of the costs assessed to the
Company are included in deferred policy acquisition costs.

<PAGE>
PAGE 64
7. Commitments and contingencies

At Dec. 31, 1993 and 1992, traditional life insurance and universal
life-type insurance in force aggregated $2,933,830 and $2,785,218,
respectively, of which $172,973 and $179,976 were reinsured at the
respective year ends. 

In addition, the Company has a "stop loss" reinsurance agreement
with IDS Life covering ordinary life benefits.  IDS Life agrees to
pay all death benefits incurred each year which exceed 125 percent
of normal claims, where "normal" claims are defined in the
agreement as .095 percent of the mean retained life insurance in
force.  Premiums ceded to IDS Life amounted to $67, $60 and $135
for the years ended Dec. 31, 1993, 1992 and 1991, respectively. 
Claim recoveries under the terms of this reinsurance agreement were
$nil in 1993, $534 in 1992 and $323 in 1991.

Premiums ceded to reinsurers other than IDS Life amounted to $741,
$773 and $800 for the years ended Dec. 31, 1993, 1992 and 1991,
respectively.  Reinsurance recovered from reinsurers other than IDS
Life amounted to $379, $186 and $(50) for the years ended Dec.
31, 1993, 1992 and 1991. 
      
Reinsurance contracts do not relieve the Company from its primary
obligations to policyholders.

The Company has an agreement to assume a block of extended term
life insurance business.  The amount of insurance in force related
to this agreement was $512,555 and $592,792 at Dec. 31, 1993 and
1992, respectively.  The accompanying statement of income includes
premiums of $nil for the years ended Dec. 31, 1993, 1992 and 1991,
and decrease in liabilities for future policy benefits of $3,032,
$3,825 and $4,088 related to this agreement for the years ended
Dec. 31, 1993, 1992 and 1991, respectively.
      
8. Line of credit

The Company has an available line of credit with a bank aggregating
$20,000 at 80 basis points over the bank's cost  of funds. 
Outstanding borrowings under this agreement were $1,519 and $nil at
Dec. 31, 1993 and 1992, respectively.
    
<PAGE>
PAGE 65
PART C.

Item 24.  Financial Statements and Exhibits

(a)  Financial Statements included in Part B of this Registration
     Statement.

     IDS Life of New York Accounts 4, 5, 6, 9, 10 and 11:

     Report of Independent Auditors dated March 18, 1994.
     Statements of Net Assets at Dec. 31, 1993.
     Statements of Operations for the year ended Dec. 31, 1993.
     Statements of Changes in Net Assets for the years ended
          Dec. 31, 1993 and Dec. 31, 1992.
     Notes to Financial Statements.

     IDS Life Insurance Company of New York

     Report of Independent Auditors dated February 3, 1994.
     Balance Sheets at Dec. 31, 1993 and 1992;
     Statements of Income for the years ended Dec. 31, 1993, 1992,
          and 1991;
     Statements of Cash Flows for the years ended Dec. 31, 1993, 
          1992, and 1991;
     Notes to Financial Statements.

     Exhibits to Financial Statements included in Part B:

     Report of Independent Auditors dated February 3, 1994.

     Financial Statement Schedules I, V, VI, VIII and IX as
     required by Regulation S-X:
     
     Schedule I - Summary of Investments Other than Investments in
          Related Parties
     Schedule V - Supplementary Insurance Information
     Schedule VI - Reinsurance
     Schedule VIII - Valuation and Qualifying Accounts
     Schedule IX - Short-Term Borrowings

     All other schedules to the financial statements required by
     Article 7 of Regulation S-X are not required under the related
     instructions or are inapplicable and, therefore have been
     omitted.

(b)  Exhibits:

1.1  Resolution of the Executive Committee of the Board of
     Directors of IDS Life of New York dated Nov. 12, 1981, was
     filed electronically as Exhibit 1.1 to Post-Effective
     Amendment No. 20 to Registration Statement No. 2-73114 is
     incorporated herein by reference.

1.2  Resolution of the Board of Directors of IDS Life of New York
     establishing Account 9 on Feb. 12, 1988, was filed
     electronically as Exhibit 1.2 to Post-Effective Amendment No.
     20 to Registration Statement No. 2-73114 is incorporated
     herein by reference.

<PAGE>
PAGE 66
1.3  Resolution of the Board of Directors of IDS Life Insurance
     Company of New York establishing Accounts 10 and 11 on Oct. 8,
     1991, was filed electronically as Exhibit 1.3 to Post-
     Effective Amendment No. 20 to Registration Statement No. 2-
     73114 is incorporated herein by reference.

2.   Not applicable.

3.   Form of Variable Annuity and Life Insurance Distribution
     Agreement was filed electronically as Exhibit 3 to Post-
     Effective Amendment No. 20 to Registration Statement No. 2-
     73114 is incorporated herein by reference.

4.1  Copy of form of Qualified Deferred Annuity Contract (form
     39192) was filed electronically as Exhibit 4.1 to Post-
     Effective Amendment No. 20 to Registration Statement No. 2-
     73114 is incorporated herein by reference.

4.2  Copy of form of Non-Qualified Deferred Annuity Contract (form
     39191), filed electronically herewith.

4.3  Copy of form of Deferred Annuity Contract (IRA) (form 39192
     IRA), filed electronically herewith.

5.1  Application form for the Contracts filed as Exhibit 10 to the
     IDS Life of New York Accounts 4, 5 and 6 Registration
     Statement 2-78194, is incorporated herein by reference.

5.2  Copy of Form of Application for IDS Life of New York Annuity
     Contract, was filed electronically as Exhibit 5.2 to Post-
     Effective Amendment No. 20 to Registration Statement No. 2-
     73114 is incorporated herein by reference.

6.1  Revised Charter of IDS Life of New York dated April, 1992,
     filed electronically herewith.

6.2  By-Laws of IDS Life of New York dated May, 1992, filed
     electronically herewith.

7.   Not applicable.

8.   Not applicable.

9.   Opinion of counsel as to the legality of the securities being
     registered and consent to its use was filed with Registrant's
     24f-2 Notice on or about February 25, 1994.

10.  Consent of Independent Auditors, filed electronically
     herewith.

11.  Financial Statement Schedules and Report of Independent
     Auditors, filed electronically herewith.

12.  Not applicable.

13.  Not applicable.

<PAGE>
PAGE 67
14.1 Not applicable.

14.2 Power of Attorney, dated April 18, 1994, filed electronically
     herewith.
<PAGE>
PAGE 68
Item 25.  Directors and Officers of the Depositor
<TABLE>
<CAPTION>
                         Positions and                                Positions and
Name & Principal         Offices with         Name & Principal        Offices with
Business Address         Depositor            Business Address        Depositor    
<S>                      <C>                  <C>                     <C>
Gary A. Beller           Director             James A. Mitchell       Chairman of the
American Express Plaza                        IDS Tower 10            Board, President
New York, NY                                  Minneapolis, MN         and Director

John C. Boeder           Director,            Michael P. Monaco       Director
Box 5144                 Vice President,      Box 5144
Albany, NY  12205        Chief Operating      Albany, NY 12205
                         Officer
                                              Stephen P. Norman       Director
Paul V. Bruce            Qualified            American Express
IDS Tower 10             Actuary              Plaza
Minneapolis, MN                               New York, NY

Michael B. Carlin        Claims Officer,      Gordon H. Ritz          Director
Box 5144                 Secretary and        404 WCCO Radio Bldg.
Albany, NY               General Counsel      Minneapolis, MN

Roger C. Corea           Director             Michael R. Woodward     Director
345 Woodcliff Drive                           45 Liberty St.
Fairport, NY  14450                           Batavia, NY  14020

Charles A. Cuccinello    Director
25 Dogwood Drive
Scarsdale, NY

Francis M. Ellis         Director
90 Greene St.
New York, NY  10012

Milton Fenster           Director
540 Madison Ave.
New York, NY

Donna Gaglione           Treasurer
Box 5144
Albany, NY  12205

Margaret Grogan, M.D.    Medical
Bethlehem Terrace Apts   Director
Slingerland, NY

David R. Hubers          Director
IDS Tower 10
Minneapolis, MN

Richard W. Kling         Director
IDS Tower 10
Minneapolis, MN

Edward Landes            Director
30 South 9th Street
Minneapolis, MN
/TABLE
<PAGE>
PAGE 69
Item 26.  Persons Controlled by or Under Common Control with the
          Depositor or Registrant

          IDS Life Insurance Company of New York is a wholly owned
          subsidiary of IDS Life Insurance Company which is a
          wholly owned subsidiary of IDS Financial Corporation. 
          IDS Financial Corporation is a wholly owned subsidiary of
          American Express Company (American Express).

          The following list includes the names of major
          subsidiaries of American Express.  

                                                  Jurisdiction
Name of Subsidiary                                of Incorporation

I.   Travel Related Services

     American Express Travel Related 
     Services Company, Inc.                       New York

II.  International Banking Services

     American Express Bank Ltd.                   Connecticut

III. Investment Services

     Lehman Brothers Inc.                         Delaware

IV.  Companies engaged in Investors 
     Diversified Financial Services

     American Enterprise Investment Services Inc.   Minnesota
     American Enterprise Life Insurance Company     Indiana
     American Express Minnesota Foundation          Minnesota
     American Express Service Corporation           Delaware
     American Partners Life Insurance Company       Minnesota
     IDS Advisory Group Inc.                        Minnesota
     IDS Aircraft Services Corporation              Minnesota
     IDS Cable Corporation                          Minnesota
     IDS Cable II Corporation                       Minnesota
     IDS Capital Holdings Inc.                      Minnesota
     IDS Certificate Company                        Delaware
     IDS Deposit Corp.                              Utah
     IDS Financial Corporation                      Delaware
     IDS Financial Services Inc.                    Delaware
     IDS Fund Management Limited                    U.K.
     IDS Futures Corporation                        Minnesota
     IDS Futures III Corporation                    Minnesota
     IDS Insurance Agency of Alabama Inc.           Alabama
     IDS Insurance Agency of Arkansas Inc.          Arkansas
     IDS Insurance Agency of Massachusetts Inc.     Massachusetts
     IDS Insurance Agency of Mississippi Inc.       Mississippi
     IDS Insurance Agency of Nevada Inc.            Nevada
     IDS Insurance Agency of New Mexico Inc.        New Mexico
<PAGE>
PAGE 70
Item 26.  Persons Controlled by or Under Common Control with the
          Depositor or Registrant (Continued)

                                                  Jurisdiction
Name of Subsidiary                                of Incorporation

     IDS Insurance Agency of North Carolina Inc.    North Carolina
     IDS Insurance Agency of Ohio Inc.              Ohio
     IDS Insurance Agency of Texas Inc.             Texas
     IDS Insurance Agency of Utah Inc.              Utah
     IDS Insurance Agency of Wyoming Inc.           Wyoming
     IDS International, Inc.                        Delaware
     IDS Life Insurance Company                     Minnesota
     IDS Life Insurance Company of New York         New York
     IDS Management Corporation                     Minnesota
     IDS Partnership Services Corporation           Minnesota
     IDS Plan Services of California, Inc.          Minnesota
     IDS Property Casualty Insurance Company        Wisconsin
     IDS Real Estate Services, Inc.                 Delaware
     IDS Realty Corporation                         Minnesota
     IDS Sales Support Inc.                         Minnesota
     IDS Securities Corporation                     Delaware
     IDS Trust Company                              Minnesota
     Investors Syndicate Development Corp.          Nevada

Item 27.  Number of Contractowners

          On March 31, 1994, there were 2,090 contract owners of
          qualified Combination Retirement Annuity contracts. 
          There were no owners of non-qualified contracts.

          There were 46 owners of qualified Variable Retirement
          Annuity contracts.  There were 306 owners of non-
          qualified contracts.

Item 28.  Indemnification

          The By-Laws of the depositor provide that it shall
          indemnify any person made a party to an action or
          proceeding by or in the right of the depositor to procure
          a judgment in its favor, by reason of the fact that he,
          his testator or intestate, is or was a director or
          officer or employee of the depositor against the
          reasonable expenses, including attorneys' fees, actually
          and necessarily incurred by him in connection with the
          defense of such action or proceeding, or in connection
          with the appeal therein, except in relation to matters as
          to which such person is adjudged to have breached his
          duty to the depositor; and

          The depositor shall indemnify any person made, or
          threatened to be made a party to an action or proceeding
          other than one by or in the right of the depositor to
          procure a judgment in its favor, whether civil or
          criminal, including an action by or in the right of any 
<PAGE>
PAGE 71
          other corporation of any type or kind domestic or
          foreign, which any director or officer or employee of the
          depositor served in any capacity at the request of the
          depositor, by reason of the fact that he, his testator or
          intestate, was a director or officer of employee of the
          depositor, or served such other corporation in any
          capacity, against judgments, fines, amounts paid in
          settlement and reasonable expenses, including attorneys'
          fees, actually and necessarily incurred as a result of 
          such action or proceeding, or any appeal therein, if such
          person acted in good faith, for a purpose which he
          reasonably believed to be in the best interests of the
          depositor and, in criminal actions or proceedings, in
          addition had no reasonable cause to believe that his
          conduct was unlawful.

Insofar as indemnification for liability arising under the
Securities Act of 1933 may be permitted to director, officers and
controlling persons of the registrant pursuant to the foregoing
provisions, or otherwise, the registrant has been advised that in
the opinion of the Securities and Exchange Commission such
indemnification is against public policy as expressed in the Act
and is, therefore, unenforceable.  In the event that a claim for
indemnification against such liabilities (other than the payment by
the registrant of expenses incurred or paid by a director, officer
or controlling person of the registrant in the successful defense
of any action, suit or proceeding) is asserted by such director,
officer or controlling person in connection with the securities
being registered, the registrant will, unless in the opinion of its
counsel the matter has been settled by controlling precedent,
submit to a court of appropriate jurisdiction the question whether
such indemnification by it is against public policy as expressed in
the Act and will be governed by the final adjudication of such
issue.

Item 29.   Principal Underwriters.

(a)  IDS Financial Services Inc. acts as  principal underwriter for
     the following investment companies:

   IDS Blue Chip Advantage Fund; IDS Bond Fund, Inc.; IDS
   California Tax-Exempt Fund; IDS Cash Management Fund, Inc.; IDS
   Discovery Fund, Inc,; IDS Diversified Equity Income Fund; IDS
   Equity Plus Fund, Inc.; IDS Extra Income Fund, Inc.; IDS
   Federal Income Fund, Inc.; IDS Global Bond Fund, Inc.; IDS
   Global Growth Fund; IDS Growth Fund, Inc.; IDS High Yield Tax-
   Exempt Fund, Inc.; IDS Insured Tax-Exempt Fund; IDS
   International Fund, Inc.; IDS Managed Retirement Fund, Inc.;
   IDS Massachusetts Tax-Exempt Fund; IDS Michigan Tax-Exempt
   Fund; IDS Minnesota Tax-Exempt Fund; IDS Mutual; IDS New
   Dimensions Fund, Inc.; IDS New York Tax-Exempt Fund; IDS Ohio
   Tax-Exempt Fund; IDS Planned Investment Account; IDS Precious
   Metals Fund, Inc.; IDS Progressive Fund, Inc.; IDS Selective
   Fund, Inc.; IDS Stock Fund, Inc.; IDS Strategy Fund, Inc.; IDS
   Tax-Exempt Bond Fund, Inc.; IDS Tax-Free Money Fund, Inc.; IDS
   Utilities Income Fund, Inc. and IDS Certificate Company.

<PAGE>
PAGE 72
(b)  As to each director, officer or partner of the principal
     underwriter:
                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

Ronald G. Abrahamson     Vice President-              None
IDS Tower 10             Field Administration
Minneapolis, MN 55440

Douglas A. Alger         Vice President-Total         None
IDS Tower 10             Compensation
Minneapolis, MN 55440

Jerome R. Amundson       Vice President and           None
IDS Tower 10             Controller-Mutual Funds
Minneapolis, MN 55440    Operations

Peter J. Anderson        Senior Vice President-       None
IDS Tower 10             Advisory Group and
Minneapolis, MN 55440    Equity Management

Ward D. Armstrong        Vice President-              None
IDS Tower 10             Sales and Marketing,
Minneapolis, MN  55440   IDS Institutional Retirement
                         Services

Alvan D. Arthur          Region Vice President-       None
IDS Tower 10             Pacific Northwest Region
Minneapolis, MN  55440

Kent L. Ashton           Vice President-Group         None
IDS Tower 10             Management Office,
Minneapolis, MN 55440    Banking and Certificates
                         Group

Joseph M. Barsky III     Vice President-Senior        None
IDS Tower 10             Portfolio Manager
Minneapolis, MN  55440

Robert Baston            Vice President-Tax           None
IDS Tower 10             and Business Services
Minneapolis, MN  55440

Timothy V. Bechtold      Vice President-Insurance     None
IDS Tower 10             Product Development
Minneapolis, MN  55440

John D. Begley           Region Vice President-       None
Olentangy Valley Center  Mid-Central Region
Suite 300
7870 Olentangy River Rd.
Columbus, OH  43235

Carl E. Beihl            Vice President-              None
IDS Tower 10             Strategic Technology
Minneapolis, MN 55440    Planning
<PAGE>
PAGE 73
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

Alan F. Bignall          Vice President-              None
IDS Tower 10             Financial Planning
Minneapolis, MN 55440    Systems

Brent L. Bisson          Region Vice President-       None
Seafirst Financial       Northwest Region
Center, Suite 1730
601 W. Riverside Ave.
Spokane, WA 99201

Karl J. Breyer           Senior Vice President        None
IDS Tower 10             and Special Counsel
Minneapolis, MN 55440

Harold E. Burke          Vice President               None
IDS Tower 10             and Assistant 
Minneapolis, MN 55440    General Counsel

Daniel J. Candura        Vice President-              None
IDS Tower 10             Marketing Support
Minneapolis, MN  55440

Cynthia M. Carlson       Vice President-IDS           None
IDS Tower 10             Securities Services
Minneapolis, MN  55440

Orison Y. Chaffee III    Vice President-Field         None
IDS Tower 10             Real Estate
Minneapolis, MN 55440

James E. Choat           Senior Vice President-       None
Suite 124                Field Management
6210 Campbell Rd.
Dallas, TX 75248

Kenneth J. Ciak          Vice President and           None
IDS Property Casualty    General Manager-
1400 Lombardi Avenue     IDS Property Casualty
Green Bay, WI 54304

Roger C. Corea           Region Vice President-       None
345 Woodcliff Drive      Northeast Region
Fairport, NY  14450

Kevin F. Crowe           Region Vice President-       None
IDS Tower 10             Atlantic Region
Minneapolis, MN 55440    

Alan R. Dakay            Vice President-              None
IDS Tower 10             Institutional Insurance
Minneapolis, MN 55440    Marketing
<PAGE>
PAGE 74
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

William F. Darland       Region Vice President-       None
Suite 108C               South Central Region
301 Sovereign Court
Manchester, MO 63011

William H. Dudley        Director, Executive          Director/
IDS Tower 10             Vice President-              Trustee
Minneapolis MN 55440     Investment and Brokerage
                         Operations

Roger S. Edgar           Senior Vice President-       None
IDS Tower 10             Information Systems
Minneapolis, MN 55440

Gordon L. Eid            Senior Vice President        None
IDS Tower 10             and General Counsel
Minneapolis, MN 55440

Mark A. Ernst            Vice President-              None
IDS Tower 10             Tax and Business Services
Minneapolis, MN 55440

Gordon M. Fines          Vice President-              None
IDS Tower 10             Mutual Fund Equity
Minneapolis MN 55440     Investments

Louis C. Fornetti        Senior Vice President-       None
IDS Tower 10             Corporate Controller
Minneapolis, MN 55440

Douglas L. Forsberg      Vice President-              None
IDS Tower 10             Securities Services
Minneapolis, MN 55440

Carl W. Gans             Region Vice President-       None
IDS Tower 10             North Central Region
Minneapolis, MN  55440

Robert G. Gilbert        Vice President-              None
IDS Tower 10             Real Estate
Minneapolis, MN 55440

John J. Golden           Vice President-              None
IDS Tower 10             Field Compensation
Minneapolis, MN  55440   Development

Morris Goodwin Jr.       Vice President and           None
IDS Tower 10             Corporate Treasurer
Minneapolis, MN 55440

<PAGE>
PAGE 75
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

Suzanne Graf             Vice President-              None
IDS Tower 10             Systems Services
Minneapolis, MN  55440

David A. Hammer          Vice President               None
IDS Tower 10             and Marketing
Minneapolis, MN  55440   Controller

Robert L. Harden         Region Vice President-       None
Suite 403                Mid-Atlantic Region
8500 Leesburg Pike
Vienna, VA  22180

Lorraine R. Hart         Vice President-              None
IDS Tower 10             Insurance Investments
Minneapolis, MN 55440

Mark S. Hays             Vice President-Senior        None
IDS Tower 10             Portfolio Manager, IDS
Minneapolis, MN 55440    International

Brian M. Heath           Region Vice President-       None
IDS Tower 10             Southwest Region
Minneapolis, MN  55440

Raymond E. Hirsch        Vice President-Senior        None
IDS Tower 10             Portfolio Manager
Minneapolis, MN 55440

James G. Hirsh           Vice President and           None
IDS Tower 10             Assistant General
Minneapolis, MN  55440   Counsel

Kevin P. Howe            Vice President-              None
IDS Tower 10             Government and
Minneapolis, MN  55440   Customer Relations

David R. Hubers          Chairman, Chief              None
IDS Tower 10             Executive Officer and
Minneapolis, MN 55440    President

Marietta Johns           Senior Vice President-       None
IDS Tower 10             ACUMA Ltd.
Minneapolis, MN 55440

Douglas R. Jordal        Vice President-Taxes         None
IDS Tower 10
Minneapolis, MN 55440

<PAGE>
PAGE 76
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

Craig A. Junkins         Vice President - IDS 1994    None
IDS Tower 10             Implementation Planning
Minneapolis, MN 55440    and Financial Planning
                         Development

James E. Kaarre          Vice President-              None
IDS Tower 10             Marketing Information
Minneapolis, MN  55440

G. Michael Kennedy       Vice President-Investment    None
IDS Tower 10             Services and Investment
Minneapolis, MN  55440   Research

Susan D. Kinder          Senior Vice President-       None
IDS Tower 10             Human Resources
Minneapolis, MN 55440

Richard W. Kling         Vice President-              None
IDS Tower 10             Insurance Marketing
Minneapolis, MN  55440   and Products

Harold D. Knutson        Vice President-              None
IDS Tower 10             System Services
Minneapolis, MN 55440

Paul F. Kolkman          Vice President-              None
IDS Tower 10             Corporate Actuary
Minneapolis, MN 55440

Claire Kolmodin          Vice President-              None
IDS Tower 10             Service Quality
Minneapolis, MN  55440

David S. Kreager         Vice President-Field         None
IDS Tower 10             Management Development
Minneapolis, MN  55440

Christopher R. Kudrna    Vice President-              None
IDS Tower 10             Systems and Technology
Minneapolis, MN  55440   Development

Steven C. Kumagai        Director, Senior Vice        None
IDS Tower 10             President and Associate
Minneapolis, MN 55440    General Sales Manager

Mitre Kutanovski         Region Vice President-       None
IDS Tower 10             Midwest Region
Minneapolis, MN  55440

<PAGE>
PAGE 77
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

Edward Labenski          Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN 55440    Manager

Peter L. Lamaison        Vice President-              None
One Broadgate            IDS International
London, England          Division

Kurt A. Larson           Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN  55440   Manager

Ryan R. Larson           Vice President-              None
IDS Tower 10             Annuity Product
Minneapolis, MN 55440    Development

Daniel E. Laufenberg     Vice President and           None
IDS Tower 10             Chief U.S. Economist
Minneapolis, MN  55440

Douglas A. Lennick       Director, Senior Vice        None
IDS Tower 10             President and General 
Minneapolis, MN  55440   Sales Manager

Mary J. Malevich         Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN 55440    Manager

Fred A. Mandell          Vice President-              None
IDS Tower 10             Certificate Operations
Minneapolis, MN  55440

William J. McKinney      Vice President-              None
IDS Tower 10             Field Management
Minneapolis, MN  55440   Support

Thomas W. Medcalf        Vice President-              None
IDS Tower 10             Senior Portfolio Manager
Minneapolis, MN 55440

William C. Melton        Vice President-              None
IDS Tower 10             International Research
Minneapolis, MN 55440    and Chief International 
                         Economist

Janis E. Miller          Vice President-Mutual        None
IDS Tower 10             Funds Products and
Minneapolis, MN 55440    Marketing

<PAGE>
PAGE 78
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

James A. Mitchell        Senior Vice President-       None
IDS Tower 10             Insurance Operations
Minneapolis, MN 55440

Pamela J. Moret          Vice President-              None
IDS Tower 10             Corporate Communications
Minneapolis, MN 55440    

Robert J. Neis           Vice President-              None
IDS Tower 10             Information Systems
Minneapolis, MN 55440    Operations

Vernon F. Palen          Region Vice President-       None
Suite D-222              Rocky Mountain Region
7100 E. Lincoln Drive
Scottsdale, AZ  85253

James R. Palmer          Vice President-              None
IDS Tower 10             Insurance Operations
Minneapolis, MN 55440

Judith A. Pennington     Vice President-              None
IDS Tower 10             Field Technology
Minneapolis, MN  55440

George M. Perry          Vice President-              None
IDS Tower 10             Corporate Strategy
Minneapolis, MN 55440    and Development

Susan B. Plimpton        Vice President-              None
IDS Tower 10             American Express 
Minneapolis, MN 55440    Marketing

Ronald W. Powell         Vice President and           None
IDS Tower 10             Assistant General
Minneapolis, MN 55440    Counsel

James M. Punch           Vice President-              None
IDS Tower 10             TransAction Services
Minneapolis, MN 55440

Frederick C. Quirsfeld   Vice President-Taxable       None
IDS Tower 10             Mutual Fund Investments
Minneapolis, MN 55440

Roger B. Rogos           Region Vice President-       None
Suite 15, Parkside Place Great Lakes Region
945 Boardman-Canfield Rd
Youngstown, Ohio  44512

<PAGE>
PAGE 79
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

ReBecca K. Roloff        Vice President-1994          None 
IDS Tower 10             Program Director
Minneapolis, MN  55440   

Stephen W. Roszell       Vice President-              None
IDS Tower 10             Advisory Institutional
Minneapolis, MN  55440   Marketing

Robert A. Rudell         Vice President-              None
IDS Tower 10             IDS Institutional   
Minneapolis, MN 55440    Retirement Services

John P. Ryan             Vice President and           None
IDS Tower 10             General Auditor
Minneapolis, MN 55440

Erven A. Samsel          Senior Vice President-       None
45 Braintree Hill Park   Field Management
Braintree, MA 02184

R. Reed Saunders         Director, Senior             None
IDS Tower 10             Vice President and
Minneapolis, MN  55440   Chief Marketing Officer

Stuart A. Sedlacek       Vice President-              None
IDS Tower 10             Structured Products
Minneapolis, MN  55440   Group

Donald K. Shanks         Vice President-              None
IDS Tower 10             Property Casualty
Minneapolis, MN  55440

F. Dale Simmons          Vice President-Senior        None
IDS Tower 10             Portfolio Manager,
Minneapolis, MN 55440    Insurance Investments

Judy P. Skoglund         Vice President-              None
IDS Tower 10             Human Resources and
Minneapolis, MN  55440   Organization Development

Julian W. Sloter         Region Vice President-       None
9040 Roswell Rd.         Southeast Region
River Ridge-Suite 600
Atlanta, GA  30350

Ben C. Smith             Vice President-              None
IDS Tower 10             Workplace Marketing
Minneapolis, MN  55440

<PAGE>
PAGE 80
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

William A. Smith         Vice President-              None
IDS Tower 10             Finance and CFO/UK
Minneapolis, MN 55440

James B. Solberg         Vice President-              None
IDS Tower 10             Advanced Financial
Minneapolis, MN 55440    Planning

Bridget Sperl            Vice President-              None
IDS Tower 10             Human Resources
Minneapolis, MN 55440    Management Services

Lois A. Stilwell         Vice President-              None
IDS Tower 10             Sales Training and
Minneapolis, MN  55440   Communications

William A. Stoltzmann    Vice President and           None
IDS Tower 10             Assistant General
Minneapolis, MN 55440    Counsel

James J. Strauss         Vice President-              None
IDS Tower 10             Corporate Planning
Minneapolis, MN 55440    and Analysis

Jeffrey J. Stremcha      Vice President-Information   None
IDS Tower 10             Resource Management/ISD
Minneapolis, MN  55440

Neil G. Taylor           Vice President-              None
IDS Tower 10             Field Business Systems
Minneapolis, MN 55440

John R. Thomas           Senior Vice President-       Director/
IDS Tower 10             Mutual Funds Operations      Trustee
Minneapolis, MN 55440

Melinda S. Urion         Vice President-              None
IDS Tower 10             Insurance Controller
Minneapolis, MN 55440

Wesley W. Wadman         Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN 55440    Manager

Norman Weaver Jr.        Senior Vice President-       None
Suite 215                Field Management
1501 Westcliff Drive
Newport Beach, CA  92660

<PAGE>
PAGE 81
Item 29.  (Continued)

                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant 

Michael L. Weiner        Vice President-              None
IDS Tower 10             Corporate Tax
Minneapolis, MN 55440    Operations

Lawrence J. Welte        Vice President-              None
IDS Tower 10             Investment Administration
Minneapolis, MN  55440

William N. Westhoff      Senior Vice President-       None
IDS Tower 10             Fixed Income Management
Minneapolis, MN  55440

Edwin M. Wistrand        Vice President and           None
IDS Tower 10             Assistant General
Minneapolis, MN 55440    Counsel

Michael R. Woodward      Senior Vice President-       None
Suite 815                Field Management
8585 Broadway
Merrillville, IN  46410
<TABLE>
<CAPTION>
(c) Name of       Net Underwriting
    Principal     Discounts and      Compensation on    Brokerage     Other
    Underwriter   Commissions           Redemption      Commissions   Compensation
    <S>               <C>            <C>                   <C>            <C>
    IDS Financial
    Services Inc.     None           $151,536              None           None
</TABLE>
* Surrender charges received by IDS Life of New York.

Item 30.         Location of Accounts and Records

                 IDS Life Insurance Company of New York
                 20 Madison Avenue Extension
                 Albany, NY  12203

Item 31.         Management Services

                 Not applicable.

Item 32.         Undertakings

(a) (b) & (c)    These undertakings were filed with the
                 Registrant's initial Registration Statements,
                 File Nos. 2-78194 and 811-3500.

(d)              Registrant represents that it is relying upon the
                 no-action assurance given to the American Council
                 of Life Insurance (pub. avail. Nov. 28, 1989). 
                 Further, Registrant represents that it has
                 complied with the provisions of paragraphs (1)-
                 (4) of that no-action letter.
<PAGE>
PAGE 82
                            SIGNATURES

As required by the Securities Act of 1933 and the Investment
Company Act of 1940, IDS Life Insurance Company of New York, on
behalf of the Registrant certifies that it meets the requirements
of Securities Act Rule 486(b) for effectiveness of this
Registration Statement and has caused this Registration Statement
to be signed on its behalf, in the City of Minneapolis, and State
of Minnesota, on this 25th day of April, 1994.

                                     IDS LIFE ACCOUNT 4
                                     IDS LIFE ACCOUNT 5
                                     IDS LIFE ACCOUNT 6
                                     IDS LIFE ACCOUNT 9
                                     IDS LIFE ACCOUNT 10
                                     IDS LIFE ACCOUNT 11           
                                         (Registrant)

                          By IDS Life Insurance Company of New York
                                          (Sponsor)

                          By/s/ Richard W. Kling*                  
                                Richard W. Kling
                                President

As required by the Securities Act of 1933, this Registration
Statement has been signed by the following persons in the
capacities indicated on this 25th day of April, 1994.

Signature                               Title

/s/ Richard W. Kling*                   Director and President
    Richard W. Kling

/s/ John C. Boeder*                     Director and Chief 
    John C. Boeder                      Operating Officer

/s/ Roger C. Corea                      Director
    Roger C. Corea

/s/ Charles A. Cuccinello*              Director
    Charles A. Cuccinello

/s/ Milton R. Fenster*                  Director
    Milton R. Fenster

/s/ Edward Landes*                      Director
    Edward Landes

/s/ Michael P. Monaco*                  Director
    Michael P. Monaco

/s/ Stephen P. Norman*                  Director
    Steven P. Norman

/s/ Louise M. Parent*                   Director
    Louise M. Parent
<PAGE>
PAGE 83
Signature                               Title

/s/ Carl Platou*                        Director
    Carl Platou

/s/ Gordon H. Ritz*                     Director
    Gordon H. Ritz

/s/ Michael R. Woodward*                Director
    Michael R. Woodward


*Signed pursuant to Power of Attorney dated April 18, 1994, filed
electroncially herewith.



_______________________________
Mary Ellyn Minenko 
<PAGE>
PAGE 84
             CONTENTS OF REGISTRATION STATEMENT NO. 21

This Registration Statement is comprised of the following papers
and documents:

The Cover Page.

Cross-reference sheet.

Part A.

     The prospectus.

Part B.

     Statement of Additional Information.

     Financial Statements.

Part C.

     Other Information.

     The signatures.

Exhibits.


<PAGE>
PAGE 1
EXHIBIT INDEX

4.2  Copy of form of Non-Qualified Deferred Annuity Contract (form
     39191).

4.3  Copy of form of Deferred Annuity Contract (IRA) (form 39192).

6.1  Revised Charter of IDS Life of New York dated April, 1992.

6.2  By-Laws of IDS Life of New York dated May, 1992.

10   Consent of Independent Auditors.

11   Financial Statement Schedules and Report of Independent
     Auditors.

14.2 Power of Attorney dated April 18, 1994.


<PAGE>
PAGE 1
IDS Life Insurance Company of New York
A Stock Company
Box 5144
Albany, New York 12205
An American Express Company

DEFERRED ANNUITY CONTRACT

- - Flexible purchase payments.
- - Optional fixed dollar or variable accumulation values and
  annuity payments.
- - Annuity payments to begin on the retirement date.
- - This contract is nonparticipating.  Dividends are not
  payable.

Annuitant:          John Doe
Contract Number:    9310-1234567
Contract Date:      April 1, 1986
Retirement Date:    April 1, 2006


This is a deferred annuity contract.  It is a legal contract
between you, as the owner, and us, IDS Life Insurance Company of
New York.  PLEASE READ YOUR CONTRACT CAREFULLY.

If the annuitant is living on the Retirement Date, we will begin to
pay you monthly annuity payments.  Any payments made by us are
subject to the terms of this contract.

We issue this contract in consideration of your application and the
payment of the purchase payments.

Signed for and issued by IDS Life Insurance Company of New York in
Albany, New York, as of the contract date shown above.

ACCUMULATION VALUES AND ANNUITY PAYMENTS, WHEN BASED ON THE
INVESTMENT RESULTS OF THE SEPARATE ACCOUNTS, ARE VARIABLE AND NOT
GUARANTEED AS TO FIXED DOLLAR AMOUNT.

NOTICE OF YOUR RIGHT TO EXAMINE THIS CONTRACT FOR 10 DAYS  If for
any reason you are not satisfied with this contract, return it to
us or our representative within 10 days after you receive it.  We
will then cancel this contract.  Upon such cancellation we will
refund an amount equal to the sum of:  (1) the contract value; and
(2) any premium tax charges paid.  This contract will then be
considered void from its start.

President
/s/ James A. Mitchell

Secretary
/s/ Richard J. O'Brien
<PAGE>
PAGE 2
                   GUIDE TO CONTRACT PROVISIONS

Definitions                   Important words and meanings/Page 3

General Provisions            Entire contract; Incontestability;
                              Misstatement of Age; State Laws;
                              Reports to owner; Evidence of
                              survival; Protection of proceeds;
                              Payments by us; Voting rights/ Page 4

Ownership and Beneficiary     Owner rights; Change of ownership;
                              Beneficiary; Change of Beneficiary;
                              Assignment/Page 5

Payments to Beneficiary       Describes options and amounts payable
                              upon death/Page 6

Purchase Payments             Purchase payments amounts and
                              intervals; Payment limits; Allocation
                              of purchase payments/Page 7

Contract Value                Describes the fixed and variable
                              account contract values; Interest to
                              be credited; Contract administrative
                              charge; Premium taxes; Transfers of
                              Contract Values/Page 8

Fixed and Variable Accounts   Describes the variable accounts,
                              accumulation units and values; Net
                              investment factor, Mortality and
                              expense risk charge; Annuity unit
                              value/Page 9

Surrender Provisions          Surrender of the contract for its
                              surrender value; Rules for
                              surrender/Page 10

Annuity Provisions            When annuity payments begin;
                              Different ways to receive annuity
                              payments; Determination of payment
                              amounts/Page 12

Table of Settlement Rates     Tables showing the amount of the
                              first variable annuity payment and
                              the guaranteed fixed annuity payments
                              for the various payment plans/Page 14
<PAGE>
PAGE 3
                           CONTRACT DATA

Annuitant:              John Doe
Contract Number:        Sample
Contract Owner:         John Doe
Contract Date:          April 1, 1986
Retirement Date:        April 1, 2006

Upon issuance of this contract your purchase payments have been
scheduled to be paid and applied to the fixed and variable accounts
as shown below.  You may change the amount, frequency and
allocations as provided in this contract.  Refer to the purchase
payments provisions on Page 7.

Lump Sum Single Purchase Payment Only:  None
Scheduled Purchase Payments:            Annual Amount: $1,200
                                        Payable:       $100 monthly

Variable                                      Purchase Payment
Accounts             Mutual Fund              Allocation Percentage
  4         IDS Life Capital Resource Fund           20%
  5         IDS Life Special Income Fund             20%
  6         IDS Life Moneyshare Fund                 20%
  9         IDS Life Managed Fund                    20%

Fixed Account                                        20%

Surrender Charge:  If you surrender all or a portion of this
contract surrender charges may apply.  See Page ____.

Contract Administrative Charge:  See page ____.

Maximum Purchase Payments Permitted

        1st contract year:     $250,000
        each contract year
        thereafter:              50,000

Annuitant:    John Doe           Contract Number:    Sample

Fixed Account
Table of Guaranteed Minimum Contract and Surrender Values
Guaranteed Interest Rate:     4% Per Year Compounded Annually

The following table shows the guaranteed minimum fixed account
contract and surrender values based on these assumptions: (1) $100
purchase payments are received and allocated 100% to the fixed
account at the beginning of each month; (2) There have been no
surrenders; (3) There are no premium tax charges.  If purchase
payments are otherwise paid or allocated or if there are
surrenders, or premium tax charges, the values below will be
adjusted in accordance with the provisions of this contract.
<PAGE>
PAGE 4
                     CONTRACT DATA (continued)

                         Guaranteed              Guaranteed
                         Minimum                 Minimum
End of                   Fixed Account           Fixed Account
Contract Year            Contract Value          Surrender Value

     1                    1201.86                 1118.21
     2                    2451.93                 2284.29
     3                    3752.01                 3500.36
     4                    5104.09                 4768.44
     5                    6510.26                 6090.61
     6                    7972.67                 7469.02
     7                    9493.57                 8989.57
     8                   11075.31                10571.31
     9                   12720.33                12216.33
     10                  14431.14                13927.14
     11                  16210.39                15706.39
     12                  18060.80                17556.80
     13                  19985.23                19481.23
     14                  21986.64                21482.64
     15                  24068.11                23564.11
     16                  26232.83                25728.83
     17                  28484.15                27980.15
     18                  30825.51                30321.51
     19                  33260.53                32756.53
     20                  35792.95                35288.95
     21                  38426.67                37922.67
     22                  41165.74                40661.74
     23                  44014.37                43510.37
     24                  46976.94                46472.94
     25                  50058.02                49554.02
     26                  53262.34                52758.34
     27                  56594.84                56090.84
     28                  60060.63                59556.63
     29                  63665.05                63161.05
     30                  67413.66                66909.66

Variable account contract and surrender values are not guaranteed. 
Information concerning contract and surrender values will be
provided to you at any time upon written request.
<PAGE>
PAGE 5
                            DEFINITIONS

The following words are used often in this contract.  When we use
these words, this is what we mean:

annuitant
The person on whose life monthly annuity payments depend.

you, your
The owner of this contract.  The owner may be someone other than
the annuitant.  The owner is shown in the application unless the
owner has been changed as provided in this contract.

we, our, us
IDS Life Insurance Company of New York.

accumulation unit
An accumulation unit is an accounting unit of measure.  It is used
to calculate the contract value prior to settlement.

annuity unit
An annuity unit is an accounting unit of measure.  It is used to
calculate the value of annuity payments from the variable accounts
on and after the retirement date.

contract date
It is the date from which contract anniversaries, contract years,
and contract months are determined.  Your contract date is shown
under Contract Data.

contract anniversary
The same day and month as the contract date each year that the
contract remains in force.

contract value
The sum of the: (1) Fixed Account Contract Value; and (2) Variable
Account Contract Value.

retirement date
The date shown under Contract Data on which annuity payments are to
begin.  This date may be changed as provided in this contract.

settlement
The application of the contract value of this contract to provide
annuity payments.

valuation date
A valuation date is each day the New York Stock Exchange is open
for trading.

valuation period
A valuation period is the interval of time commencing at the close
of business on each valuation date and ending at the close of
business on the next valuation date.
<PAGE>
PAGE 6
                      DEFINITIONS (continued)

fixed account
The fixed account is made up of all our assets other than those in
any separate account.

variable accounts
The variable accounts are named under Contract Data.  Each is a
separate investment account of ours.

fixed annuity
A fixed annuity is an annuity with payments which are guaranteed by
us as to dollar amount during the annuity payment period.

variable annuity
A variable annuity is an annuity with payments which (1) are not
predetermined or guaranteed as to dollar amount; and (2) vary in
amount with the investment experience of one or more of the
variable accounts.

written request
A request in writing signed by you or a Participant and delivered
to us at our home office.
<PAGE>
PAGE 7
                        GENERAL PROVISIONS

Entire Contract

This contract form is and the application form attached to it are
the entire contract between you and us.

No one except one of our corporate officers (President, Vice
President, Secretary or Assistant Secretary) can change or waive
any of our rights or requirements under this contract.  That person
must do so in writing.  None of our representatives or other
persons has the authority to change or waive any of our rights or
requirements under this contract.

In issuing this contract, we have relied upon the application.  The
statements contained in the application are considered
representations and not warranties.  No statement made in
connection with the application will be used by us to void the
contract or to deny a claim unless that statement is part of the
application.

Incontestable

After this contract has been in force during the annuitant's life
for two years from its date of issue, we cannot contest the
contract.

Misstatement of Age or Sex

If the annuitant's birthdate or sex has been misstated, payments
under this contract will be adjusted.  They will be based on what
would have been provided at the correct birthdate and sex.  Any
underpayments made by us will be made up immediately.  Any
overpayments made by us will be subtracted from future payments.

State Laws

This contract is governed by the law of the state in which it is
delivered.  The values and benefits of this contract are at least
equal to those required by such state.

Reports to Owner

At least once a year we will send you a statement showing the
contract value of this contract.  This statement will be based on
any laws or regulations that apply to contracts of this type.

Evidence of Survival

Where any payments under this contract depend on the recipient or
annuitant being alive on a given date, proof that such condition
has been met may be required by us.  Such proof may be required
prior to making the payments.

<PAGE>
PAGE 8
                  GENERAL PROVISIONS (continued)

Protection of Proceeds
Payments under this contract are not assignable by any Beneficiary
prior to the time they are due.  To the extent allowed by law,
payments are not subject to the claims of creditors or to legal
process.

Payments By Us
All sums payable by us are payable at our home office.  Any payment
of a variable annuity or surrender based on the variable contract
value shall be payable only from the variable accounts.

Voting Rights
So long as federal law requires, you may have the right to vote at
the meetings of the Variable Contract Owners.  If you have voting
rights we will send a notice to you telling you the time and place
of a meeting.  The notice will also explain matters to be voted
upon and how many votes you get.
<PAGE>
PAGE 9
                     OWNERSHIP AND BENEFICIARY

Owner's Rights
As long as the annuitant is living and unless otherwise provided in
this contract, you may exercise all rights and privileges provided
in this contract or allowed by us.

Change of Ownership 
You can change the ownership of this contract by written request on
a form approved by us.  The change must be made while the annuitant
is living.  Once the change is received by us, it will take effect
as of the date of your request, subject to any action taken or
payment made by us before the receipt.

Beneficiary
Beneficiaries are those you name, in a form satisfactory to us, to
receive benefits of this contract if you or the annuitant die while
the contract is in force.  The beneficiary is shown in the
application unless you have, since the issue date of this contract,
changed the beneficiary as provided below.

Change of Beneficiary
You may change the beneficiary anytime while the annuitant is
living by satisfactory written request to us.  Once the change is
received by us, it will take effect as of the date of your request,
subject to any action taken or payment made by us before the
receipt.

Only those beneficiaries who are living when death benefits become
payable may share in the benefits, if any.  If no beneficiary is
then living, we will pay the benefits to you, if living, otherwise
to your estate.

Assignment
While the annuitant is living, you can assign this contract or any
interest in it.  Your interest and the interest of any beneficiary
is subject to the interest of the assignee.  An assignment is not a
change of ownership and an assignee is not an owner as these terms
are used in this contract.  Any amounts payable to the assignee
will be paid in a single sum.

A copy of any assignment must be submitted to us at our home
office.  Any assignment is subject to any action taken or payment
made by us before the assignment was received at our home office. 
We are not responsible for the validity of any assignment.
<PAGE>
PAGE 10
                      PAYMENTS TO BENEFICIARY

Death Benefit Before the Retirement Date

If the annuitant or owner dies before the retirement date while
this contract is in force we will pay to the beneficiary:

1.   the greater of the contract value or the purchase payments
     paid less any amounts surrendered (if death occurred prior to
     Age 75); otherwise

2.   the contract value (if death occurred on or after Age 75).

The above amount will be payable in a lump sum upon the receipt of
due proof of death of the annuitant or owner whichever first
occurs.

In lieu of a lump sum, payment may be made under an Annuity Payment
Plan, provided:

1.   the beneficiary elects the plan within 60 days after we
     receive due proof of death; and

2.   payments begin no later than one year after the date of death;
     and

3.   the plan provides payments over a period which does not exceed
     the life of the beneficiary, or the life expectancy of the
     beneficiary.

In this event, the reference to "annuitant" in the Annuity
Provisions shall apply to the beneficiary.

Any amounts payable or applied by us as described in this section
will be based on the contract value as of the valuation date on or
next following the date on which due proof of death is received at
our Home Office.

Spouse Option to Continue Contract Upon Owner's Death

If the owner's death occurs prior to the retirement date, the
owner's spouse, if designated as sole beneficiary, may elect in
writing to forego receipt of the death benefit and instead continue
this contract in force as its owner.  The election by the spouse
must be made within 60 days after we receive due proof of death.

Annuitant's Death After the Retirement Date

If the annuitant dies after the retirement date, the amount
payable, if any, will be as provided in the Annuity Payment Plan
then in effect.
<PAGE>
PAGE 11
                         PURCHASE PAYMENTS

Purchase Payments

Purchase payments are the payments you make for this contract and
the benefits it provides.  Purchase payments must be paid or mailed
to us at our home office or to an authorized agent.  If requested,
we'll give you a receipt for your purchase payments.  Upon payment
to us, purchase payments become our property.

Net purchase payments are that part of your purchase payments
applied to the contract value.  A net purchase payment is equal to
the purchase payment less any applicable premium tax charge.

Amount and Intervals

Purchase payments may be paid in a single sum or in installments
until the earlier of:  (1) the date this contract terminates by
surrender or otherwise; or (2) the date on which annuity payments
begin.

Based upon your application we have scheduled your purchase
payments for the amount and interval as shown under Contract Data. 
Subject to the Payment Limits Provision you may:  (1) stop and/or
restart purchase payments; or (2) increase or decrease the amount
of purchase payments; or (3) change the interval of purchase
payments.

Payment Limits Provision

Maximum Purchase Payments - The maximum purchase payments in the
first or later years may not exceed the amounts shown under
Contract Data.  We reserve the right to increase the maximums.

Minimum Purchase Payments - Upon issue of this contract, a purchase
payment intended as a Single Purchase Payment must be at least
$5,000.  If you intend to make installment purchase payments such
payments, on an annualized basis, must be at least equal to $600.

We also reserve the right to cancel this contract if both of the
following conditions exist at the same time:  (1) no purchase
payments have been paid for a continuous period of 24 months; and
(2) less than $600 in purchase payments have been paid under this
contract.  In this event we will give you 30 days written notice of
our intent to cancel this contract.  Upon such cancellation we will
pay you the contract value in one sum.  This contract will then
terminate.

Allocation of Purchase Payments

You instruct us on how you want your purchase payments allocated
among the fixed account and variable accounts.  Your choice for
each account may be made in any whole percent from 0% to 100% as
long as the total adds upto 100%.  Your allocation instructions as
of the Contract Date are shown in the application.  By written
<PAGE>
PAGE 12
                   PURCHASE PAYMENTS (continued)

request, or by another method agreed to by us, you may change your
choice of accounts or percentages.  The first net purchase payment
will be allocated as of the end of the valuation period during
which we make an affirmative decision to issue this contract.  Net
purchase payments after the first will be allocated as of te end of
the valuation period during which we receive the payment at our
home office.
<PAGE>
PAGE 13
                          CONTRACT VALUE

Contract Value

The contract value at any time is the sum of: (1) the Fixed Account
Contract Value; and (2) the Variable Account Contract Value.

If: (1) part or all of the contract value is surrendered; or (2)
charges described herein are made against the contract value; then
a number of accumulation units from the variable accounts and an
amount from the fixed account will be deducted to equal such
amount.  For surrenders, deductions will be made from the fixed or
variable accounts that you specify.  Otherwise, the number of units
from the variable accounts and the amount from the fixed account
will be deducted in the same proportion that your interest in each
bears to the total contract value.

Fixed Account Contract Value

The fixed account contract value at any time will be: (1) the sum
of all amounts credited to the fixed account under this contract;
less (2) any amounts deducted for charges or surrenders.

Interest to be Credited

We will credit interest to the fixed account contract value. 
Interest will begin to accrue on the date the purchase payments
which are received in our home office become available to us for
use.  Such interest will be credited at rates that we determine
from time to time.  However, we guarantee that the rate will not be
less than the Guaranteed Interest Rate shown under Contract Data.

Variable Account Contract Value

The variable account contract value at any time will be: (1) the
sum of the value of all variable account accumulation units under
this contract resulting from purchase payments so allocated, or
transfers among the variable and fixed accounts; less (2) any units
deducted for charges or surrenders.

Contract Administrative Charge

We charge a fee for establishing and maintaining our records for
this contract.  The charge is $6 per quarter and is deducted from
the contract value at the end of each three-month period measured
from the contract date or, if earlier, when the contract is
surrendered.  The charge does not apply after settlement of this
contract.

Premium Tax Charges

A charge will be made by us against the contract value of this
contract at the time that any premium taxes not previously deducted
are payable.
<PAGE>
PAGE 14
                    CONTRACT VALUE (continued)

Transfers of Certificate Values

While this contract is in force prior to the settlement date,
transfer of contract values may be made as outlined below:

1.   You may transfer all or a part of the values held in one or
     more of the variable accounts to another one or more of the
     variable accounts.  Subject to item 2, you may also transfer
     values held in one or more of the variable accounts to the
     fixed account.

2.   On or within the 30 days after a contract anniversary you may
     transfer values from the fixed account to one of more of the
     variable accounts.  Only one such transfer is allowed during
     this period each year.  If such a transfer is made, no
     transfers from a variable account to the fixed account may be
     made until the next contract anniversary.

You may make a transfer by written request.  Transfer requests may
also be made by telephone if we have received a properly completed
authorization form.  There is no fee or charge for these transfers. 
However, the minimum transfer amount is $250, or if less, the
entire value in the account from which the transfer is being made. 
This transfer privilege may be suspended or modified by us at any
time.
<PAGE>
PAGE 15
                    FIXED AND VARIABLE ACCOUNTS

The Fixed Account

The fixed account is our general account.  It is made up of all of
our assets other than: (1) those in the variable accounts; and (2)
those in any other segregated asset account.

The Variable Accounts

The variable accounts are separate investment accounts of ours. 
They are named under Contract Data.  We have allocated a part of
our assets for this and certain other contracts to the variable
accounts.  Such assets remain our property.  However, they may not
be charged with the liabilities from any other business in which we
may take part.

Investments of the Variable Accounts

Purchase payments applied to the variable accounts will be
allocated as specified in your application for this contract or as
later changed.  Each variable account will buy, at net asset value,
shares of the fund shown for that account under Contract Data or as
later added or changed.

Valuation of Assets

Mutual fund shares in the variable accounts will be valued at their
net asset value.

Variable Account Accumulation Units

The number of accumulation units for each of the variable accounts
is found by dividing: (1) the net amount allocated to the account;
by (2) the accumulation unit value for the account for the
valuation period during which we received the purchase payment.

Variable Account Accumulation Unit Value

The value of an accumulation unit for each of the variable accounts
was arbitrarily set at $1 when the first mutual fund shares were
bought.  The value for any later valuation period is found as
follows:

     The accumulation unit value for each variable account for the
     last prior valuation period is multiplied by the net
     investment factor for the same account for the next following
     valuation period.  The result is the accumulation unit value. 
     The value of an accumulation unit may increase or decrease
     from one valuation period to the next.

<PAGE>
PAGE 16
              FIXED AND VARIABLE ACCOUNTS (continued)

Net Investment Factor

The net investment factor is an index applied to measure the
investment performance of a variable account from one valuation
period to the next.  The net investment factor may be greater or
less than one; therefore, the value of an accumulation unit may
increase or decrease.

The net investment factor for any such account for any valuation
period is determined by: dividing (1) by (2) and subtracting (3)
from the result.  This is done where:

(1) is the sum of:

     a.   the net asset value per share of the mutual fund held in
          the variable account determined at the end of the current
          valuation period; plus

     b.   the per share amount of any dividend or capital gain
          distributions made by the mutual fund held in the
          variable account, if the "ex-dividend" date occurs during
          the current valuation period.

(2)  is the net asset value per share of the mutual fund held in
     the variable account, determined at the end of the last prior
     valuation period.

(3)  is a factor representing the mortality and expense risk
     charge.

Mortality and Expense Risk Charge

In calculating accumulation unit values we will deduct a mortality
and expense risk charge from the variable accounts equal, on an
annual basis, to 1.00% of the daily net asset value.  This
deduction is made to compensate us for assuming the mortality and
expense risks under contracts of this type.  The deduction is: (1)
made from each variable account; and (2) computed on a daily basis.

Annuity Unit Value

The value of an annuity unit for each variable account was
arbitrarily set at $1 when the first mutual funds were bought.  The
value for any later valuation period is found as follows:

1.   The annuity unit for each variable account for the last prior
     valuation period is multiplied by the net investment factor
     for the account for the valuation period for which the annuity
     unit value is being calculated.

2.   The result is multiplied by an interest factor.  This is done
     to neutralize the assumed investment rate which is built into
     the annuity tables on page 14.
<PAGE>
PAGE 17
                       SURRENDER PROVISIONS

Surrender

By written request and subject to the rules below you may:

1.   surrender this contract for the total surrender value; or

2.   partially surrender this contract for a part of the surrender
     value.

Surrender Value

The surrender value at any time will be:

1.   the contract value;

2.   minus the contract administrative charge;

3.   minus any surrender charge.

Surrender Charge

In order to determine if a surrender charge applies to a partial or
total surrender we first divide the contract value into three
parts.

1.   Contract Earnings - This is the contract value minus the sum
     of all purchase payments we have received that have not been
     previously surrendered.

2.   Old Purchase Payments - These are purchase payments we
     received in any contract year more than five years prior to
     the contract year of surrender.

3.   New Purchase Payments - These are purchase payments we
     received during the contract year in which the surrender is
     made or in the five immediately preceding the contract years.

We will then surrender your contract value in the following order
so that the amount surrendered, less any surrender charge that
applies, equals your requested surrender amount:

1.   Contract Earnings, if any, are surrendered first.  There is no
     surrender charge on contract earnings.

2.   Next, if necessary, we surrender Old Purchase Payments not
     previously surrendered.  There is no surrender charge on Old
     Purchase Payments.

3.   Finally, if necessary, we surrender New Purchase Payments not
     previously surrendered.  There is a surrender charge of 7%
     applied to New Purchase Payments surrendered.
<PAGE>
PAGE 18
                 SURRENDER PROVISIONS (continued)

Surrender Charge Calculation

The surrender charge for a total surrender is calculated by
multiplying the amount representing new purchase payments by .07.

The surrender charge for a partial surrender is calculated by
dividing the surrender amount requested representing "new purchase
payments" by .93 and multiplying the result by .07.

For example, the surrender charge on a $1,000 partial surrender
request (representing all "new purchase payments") would be $75.27,
resulting from the following calculation:  ($1,000/.93 x .07 =
$75.27

Rules for Surrender

All surrenders will have the following conditions:

1.   You must apply by written request:  (a) while this contract is
     in force; and (b) prior to the earlier of the retirement date
     or the death of the annuitant.

2.   You must surrender an amount equal to at least $250.  The
     contract value after a partial surrender must be at least
     $600.

3.   The amount surrendered, less any charges, will normally be
     paid to you within seven days of the receipt of written
     request and this contract, if required.  For surrenders from
     the fixed account, we have the right to defer payment to you
     for up to 6 months from the date we receive the request.

4.   For partial surrenders, if you do not specify from which
     accounts the surrender is to be made, the surrender will be
     made from the variable accounts and fixed account in the same
     proportion as the your interest in each bears to the contract
     value.

5.   Any amounts surrendered and charges which may apply can not be
     repaid.

Upon surrender for the full surrender value this contract will
terminate.  We may require that you return the contract to us
before we pay the full surrender value.

Suspension or Delay in Payment of Surrender

We have the right to suspend or delay the date of any surrender
payment from the variable accounts for any period:

1.   When the New York Stock Exchange is closed; or

2.   When trading on the New York Stock Exchange is restricted; or
<PAGE>
PAGE 19
                 SURRENDER PROVISIONS (continued)

3.   When an emergency exists as a result of which: (a) disposal of
     securities held in the variable accounts is not reasonably
     practicable; or (b) it is not reasonably practicable to fairly
     determine the value of the net assets of the variable account;
     or

4.   During any other period when the Securities and Exchange
     Commission, by order, so permits for the protection of
     security holders.

Rules and regulations of the Securities and Exchange Commission
will govern as to whether the conditions set forth in 2 and 3
exist.
<PAGE>
PAGE 20
                        ANNUITY PROVISIONS

Settlement

When settlement occurs, the contract value will be applied to make
annuity payments.  The first payment will be made as of the
retirement date.  This date is shown under Contract Data.  Before
payments begin we will require satisfactory proof that the
annuitant is alive.  We may also require that you exchange this
contract for a supplemental contract which provides the annuity
payments.

Change of Retirement Date

You may change the retirement date shown for this contract.  Tell
us the new date by written request.  However, the retirement date
must not be later than the later of: (1) the annuitant's 85th
birthday; or (2) the tenth contract anniversary.  Also, if you
select a new date, it must be at least 30 days after we receive
your written request at our home office.

Annuity Payment Plans

Subject to the terms of this contract, annuity payments may be made
on a fixed-dollar basis, a variable basis or a combination of both. 
You can schedule receipt of annuity payment according to one of the
Plans A through E below or another plan agreed to by us.

Plan A - This provides monthly annuity payments during the lifetime
of the annuitant.  No payments will be made after the annuitant
dies.

Plan B - This provides monthly annuity payments during the lifetime
of the annuitant with a guarantee by us that payments will be made
for a period of at least five, ten or fifteen years.  You must
select the guaranteed period.

Plan C - This provides monthly annuity payments during the lifetime
of the annuitant with a guarantee by us that payments will be made
for a certain number of months.  We determine the number of months
by dividing the amount applied under this Plan by the amount of the
first monthly annuity payment.

Plan D - Monthly payments will be paid during the lifetime of the
annuitant and a joint annuitant.  When either the annuitant or the
joint annuitant dies we will continue to make monthly payments
during the lifetime of the survivor.  No payments will be paid
after the death of both the annuitant and joint annuitant.

Plan E - This provides monthly fixed dollar annuity payments for a
period of years.  The period of years may be no less than 5 nor
more than 30.
<PAGE>
PAGE 21
                  ANNUITY PROVISIONS (continued)

By written request to us at least 30 days before the Retirement
Date, you may select the Plan.  If at least 30 days before the
Retirement Date we have not received at our home office your
written request to select a Plan, we will make payments according
to Plan B with payments guaranteed for ten years.

If the amount to be applied to a Plan would not provide an initial
monthly payment of at least $20, we have the right to make a lump
sum payment of the contract value.

Fixed Annuity

A fixed annuity is an annuity with payments that are guaranteed by
us as to dollar amount.  Fixed annuity payments after the first
payment will never be less than the amount of the first payment. 
At settlement, the fixed account contract value will be applied to
the applicable Annuity Table.  This will be done in accordance with
the Payment Plan chosen.  The amount payable for each $1,000 so
applied is shown in Table B on page 15.

Variable Annuity

A variable annuity is an annuity with payments which: (1) are not
predetermined or guaranteed as to dollar amount; and (2) vary in
amount with the investment experience of the variable accounts.

Determination of First Variable Annuity Payment

At settlement, the variable account contract value will be applied
to the applicable Annuity Table.  This will be done: (1) on the
valuation date on or next preceding the seventh calendar day before
the retirement date; and (2) in accordance with the Payment Plan
chosen.  The amount payable for the first payment for each $1,000
so applied is shown in Table A on page 14.

Variable Annuity Payments After the First Payment

Variable annuity payments after the first payment vary in amount. 
The amount changes with the investment performance of the variable
accounts.  The dollar amount of variable annuity payments after the
first is not fixed.  It may change from month to month.  The dollar
amount of such payments is determined as follows:

1.   The dollar amount of the first annuity payment is divided by
     the value of an annuity unit as of the valuation date on or
     next preceding the 7th calendar day before the retirement
     date.  This result establishes the fixed number of annuity
     units for each monthly annuity payment after the first.  This
     number of annuity units remains fixed during the annuity
     payment period.
<PAGE>
PAGE 22
                  ANNUITY PROVISIONS (continued)

2.   The fixed number of annuity units is multiplied by the annuity
     unit value as of the valuation date on or next preceding the
     7th calendar day before the date the payment is due.  This
     result establishes the dollar amount of the payment.

We guarantee that the dollar amount of each payment after the first
will not be affected by variations in expenses or mortality
experience.

Exchange of Annuity Units

Annuity units of any variable account may be exchanged for units of
any of the other variable accounts.  This may be done no more than
once a year.  Once annuity payments start no exchanges may be made
to or from any fixed annuity.
<PAGE>
PAGE 23
                     TABLE OF SETTLEMENT RATES

Table A below shows the amounf of the first monthly variable
annuity payment, based on a 3-1/2% assumed investment return, for
each $1,000 of value applied under any Payment Plan.  The amount of
the first and all subsequent monthly fixed dollar annuity payments
for each $1,000 of value applied under any Payment Plan will be
based on our fixed dollar Table of Settlement Rates in effect on
the settlement dae.  Such rates are guaranteed to be not less than
those shown in Table B.  The amount of such annuity payments under
Plans A, B, and C will depend upon the sex and the adjusted age of
the annuitant on the date of settlement.  The amount of such
annuity payments under Plan D will depend upon the sex and the
adjusted age of the annuitant and joint annuitant on the date of
settlement.  Adjusted age shall be equal to the age nearest
birthday minus an "adjustment" depending on the calendar year of
birth of the annuitant as follows:

Calendar Year of                  Calendar Year of
Annuitant's Birth   Adjustment    Annuitant's Birth   Adjustment
Prior to 1920           0         1945 through 1949       6
1920 through 1924       1         1950 through 1959       7
1925 through 1929       2         1960 through 1969       8
1930 through 1934       3         1970 through 1979       9
1935 through 1939       4         1980 through 1989       10
1940 through 1944       5         After 1989              11

<PAGE>
PAGE 24
<TABLE>
<CAPTION>
               TABLE OF SETTLEMENT RATES (continued)

TABLE A  Amount of Each Monthly Annuity Payment Per $1,000 Applied                                                               

            Plan A                          Plan B                     Plan C                                                    
      Life          5 Years        10 Years       15 Years       With         Adj.      Adjusted Age of Female Joint Annuitant   
Adj.  Income        Certain        Certain        Certain        Refund       Male   10 Years   5 Years  Same   5 Years  10 Years
Age*  M      F      M       F      M       F      M       F      M      F     Age*   Younger    Younger  Age    Older    Older   
<C>   <C>    <C>    <C>     <C>    <C>     <C>    <C>     <C>    <C>    <C>   <C>    <C>        <C>      <C>    <C>      <C>
40    3.96   3.73   3.96    3.73   3.94    3.72   3.92    3.71   3.88   3.69  40     3.37       3.45     3.53   3.61     3.69
41    4.01   3.76   4.00    3.76   3.99    3.76   3.97    3.75   3.92   3.72  41     3.39       3.47     3.56   3.65     3.73
42    4.06   3.80   4.05    3.80   4.04    3.80   4.01    3.78   3.97   3.76  42     3.41       3.50     3.59   3.68     3.77
43    4.11   3.84   4.11    3.84   4.09    3.84   4.06    3.82   4.01   3.80  43     3.43       3.52     3.62   3.72     3.81
44    4.17   3.89   4.16    3.88   4.14    3.88   4.11    3.86   4.06   3.83  44     3.45       3.55     3.65   3.76     3.85

45    4.22   3.93   4.22    3.93   4.20    3.92   4.16    3.91   4.11   3.87  45     3.48       3.58     3.69   3.80     3.89
46    4.29   3.98   4.28    3.98   4.25    3.97   4.21    3.95   4.16   3.92  46     3.51       3.61     3.73   3.84     3.94
47    4.35   4.03   4.34    4.03   4.31    4.02   4.27    4.00   4.21   3.96  47     3.53       3.64     3.76   3.88     3.99
48    4.42   4.08   4.41    4.08   4.38    4.07   4.33    4.05   4.26   4.01  48     3.56       3.68     3.80   3.93     4.05
49    4.49   4.14   4.48    4.13   4.44    4.12   4.39    4.10   4.32   4.06  49     3.59       3.72     3.85   3.98     4.10

50    4.56   4.20   4.55    4.19   4.51    4.18   4.45    4.15   4.38   4.11  50     3.62       3.75     3.89   4.03     4.16
51    4.64   4.26   4.62    4.25   4.58    4.24   4.52    4.21   4.45   4.16  51     3.65       3.79     3.94   4.09     4.22
52    4.72   4.32   4.70    4.32   4.66    4.30   4.58    4.26   4.51   4.22  52     3.69       3.83     3.99   4.14     4.29
53    4.80   4.39   4.79    4.38   4.74    4.36   4.65    4.33   4.58   4.27  53     3.73       3.88     4.04   4.21     4.36
54    4.89   4.46   4.88    4.46   4.82    4.43   4.73    4.39   4.66   4.34  54     3.76       3.93     4.10   4.27     4.43

55    4.99   4.54   4.97    4.53   4.91    4.51   4.80    4.46   4.73   4.40  55     3.80       3.97     4.16   4.34     4.51
56    5.09   4.62   5.07    4.61   5.00    4.58   4.88    4.53   4.81   4.47  56     3.85       4.03     4.22   4.41     4.59
57    5.20   4.71   5.17    4.70   5.10    4.66   4.97    4.60   4.90   4.54  57     3.89       4.08     4.29   4.49     4.68
58    5.32   4.80   5.29    4.79   5.20    4.75   5.05    4.68   4.99   4.62  58     3.94       4.14     4.36   4.57     4.78
59    5.44   4.90   5.41    4.88   5.31    4.84   5.14    4.76   5.08   4.70  59     3.99       4.20     4.43   4.66     4.88

60    5.57   5.00   5.53    4.99   5.42    4.93   5.23    4.84   5.18   4.78  60     4.04       4.27     4.51   4.76     4.99
61    5.71   5.11   5.67    5.09   5.54    5.03   5.33    4.93   5.29   4.87  61     4.10       4.34     4.59   4.86     5.10
62    5.86   5.23   5.81    5.21   5.67    5.14   5.42    5.02   5.40   4.96  62     4.16       4.41     4.68   4.97     5.23
63    6.02   5.36   5.97    5.33   5.80    5.25   5.52    5.12   5.51   5.06  63     4.22       4.49     4.78   5.08     5.36
64    6.20   5.49   6.13    5.46   5.94    5.37   5.62    5.21   5.63   5.17  64     4.28       4.57     4.88   5.20     5.50

65    6.38   5.64   6.31    5.60   6.08    5.50   5.72    5.31   5.76   5.28  65     4.35       4.66     4.99   5.34     5.66
66    6.58   5.79   6.49    5.75   6.23    5.63   5.82    5.42   5.90   5.39  66     4.43       4.75     5.11   5.48     5.82
67    6.79   5.95   6.69    5.91   6.38    5.77   5.92    5.53   6.04   5.52  67     4.51       4.85     5.24   5.63     6.00
68    7.02   6.13   6.90    6.08   6.54    5.91   6.02    5.63   6.19   5.65  68     4.59       4.96     5.37   5.79     6.19
69    7.26   6.32   7.12    6.26   6.71    6.07   6.12    5.74   6.35   5.79  69     4.68       5.07     5.51   5.97     6.39

70    7.52   6.53   7.35    6.46   6.87    6.23   6.21    5.86   6.52   5.94  70     4.78       5.20     5.67   6.16     6.60
71    7.80   6.75   7.60    6.67   7.05    6.40   6.30    5.97   6.69   6.09  71     4.88       5.33     5.83   6.36     6.84
72    8.09   6.99   7.86    6.89   7.22    6.58   6.39    6.08   6.88   6.26  72     4.98       5.47     6.01   6.58     7.09
73    8.41   7.26   8.13    7.13   7.40    6.76   6.47    6.18   7.07   6.44  73     5.10       5.62     6.20   6.81     7.35
74    8.75   7.54   8.42    7.39   7.57    6.95   6.55    6.29   7.27   6.63  74     5.22       5.78     6.41   7.06     7.64

75    9.12   7.85   8.72    7.67   7.75    7.14   6.62    6.39   7.49   6.83  75     5.35       5.95     6.63   7.33     7.95
                                                                                                                                 
*Adjusted Age of annuitant.  M = *Adjusted age of annuitant.  M = Male    F = Female
                                                                                                                                 
Table A above is based on the "1983 Individual Annuitant Mortality Table A."  Settlement rates for any age, or any combination of
age and sex not shown above, will be calculated on the same basis as those rates shown in the table above.  Such rates will be
furnished by us upon request.
</TABLE>
<PAGE>
PAGE 25
<TABLE>
<CAPTION>
                              TABLE OF SETTLEMENT RATES (continued)

TABLE B  Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied                                           
             Plan A                         Plan B                     Plan C                                                    
      Life          5 Years        10 Years       15 Years       With         Adj.      Adjusted Age of Female Joint Annuitant   
Adj.  Income        Certain        Certain        Certain        Refund       Male   10 Years   5 Years  Same   5 Years  10 Years
Age*  M      F      M       F      M       F      M       F      M      F     Age*   Younger    Younger  Age    Older    Older   
<C>   <C>    <C>    <C>     <C>    <C>     <C>    <C>     <C>    <C>    <C>   <C>    <C>        <C>      <C>    <C>      <C>
40    4.27   4.04   4.26    4.04   4.25    4.03   4.23    4.02   4.20   4.01  40     3.69       3.76     3.84   3.92     4.00
41    4.31   4.07   4.31    4.07   4.30    4.07   4.27    4.06   4.24   4.04  41     3.71       3.79     3.87   3.95     4.03
42    4.36   4.11   4.36    4.11   4.34    4.10   4.32    4.09   4.28   4.07  42     3.73       3.81     3.90   3.99     4.07
43    4.42   4.15   4.41    4.15   4.39    4.14   4.36    4.13   4.32   4.11  43     3.75       3.84     3.93   4.02     4.11
44    4.47   4.19   4.46    4.19   4.44    4.18   4.41    4.17   4.37   4.15  44     3.77       3.86     3.96   4.06     4.15

45    4.53   4.24   4.54    4.23   4.50    4.23   4.46    4.21   4.42   4.19  45     3.80       3.89     3.99   4.10     4.19
46    4.59   4.28   4.58    4.28   4.55    4.27   4.51    4.25   4.47   4.23  46     3.82       3.92     4.03   4.14     4.24
47    4.65   4.33   4.64    4.33   4.61    4.32   4.56    4.30   4.52   4.27  47     3.85       3.95     4.07   4.18     4.29
48    4.72   4.38   4.71    4.38   4.67    4.37   4.62    4.34   4.58   4.32  48     3.87       3.98     4.10   4.22     4.34
49    4.79   4.44   4.77    4.43   4.74    4.42   4.68    4.39   4.63   4.36  49     3.90       4.02     4.15   4.27     4.39

50    4.86   4.50   4.85    4.49   4.81    4.47   4.74    4.45   4.69   4.41  50     3.93       4.06     4.19   4.32     4.45
51    4.94   4.56   4.92    4.55   4.88    4.53   4.80    4.50   4.76   4.47  51     3.96       4.09     4.23   4.38     4.51
52    5.02   4.62   5.00    4.61   4.95    4.59   4.87    4.56   4.82   4.52  52     4.00       4.13     4.28   4.43     4.57
53    5.10   4.69   5.08    4.68   5.03    4.66   4.94    4.62   4.90   4.58  53     4.03       4.18     4.33   4.49     4.64
54    5.19   4.76   5.17    4.75   5.11    4.72   5.01    4.68   4.97   4.64  54     4.07       4.22     4.39   4.56     4.72

55    5.29   4.84   5.26    4.83   5.20    4.80   5.09    4.74   5.05   4.71  55     4.11       4.27     4.45   4.62     4.79
56    5.39   4.92   5.36    4.91   5.29    4.87   5.17    4.81   5.13   4.77  56     4.15       4.32     4.51   4.70     4.88
57    5.49   5.00   5.47    4.99   5.38    4.95   5.25    4.88   5.21   4.85  57     4.19       4.37     4.57   4.77     4.96
58    5.61   5.09   5.58    5.08   5.40    5.03   5.33    4.96   5.30   4.92  58     4.24       4.43     4.64   4.85     5.06
59    5.73   5.19   5.70    5.17   5.59    5.12   5.42    5.04   5.40   5.00  59     4.28       4.49     4.71   4.94     5.16

60    5.86   5.29   5.82    5.27   5.70    5.22   5.51    5.12   5.50   5.09  60     4.34       4.55     4.79   5.03     5.27
61    6.00   5.40   5.96    5.38   5.82    5.32   5.60    5.21   5.60   5.18  61     4.39       4.62     4.87   5.13     5.38
62    6.16   5.52   6.10    5.50   5.95    5.42   5.69    5.30   5.72   5.27  62     4.45       4.69     4.96   5.24     5.50
63    6.32   5.65   6.26    5.62   6.08    5.53   5.79    5.39   5.83   5.37  63     4.51       4.77     5.06   5.35     5.64
64    6.49   5.78   6.42    5.75   6.21    5.65   5.89    5.49   5.96   5.48  64     4.57       4.85     5.16   5.48     5.78

65    6.68   5.92   6.60    5.89   6.35    5.77   5.98    5.58   6.09   5.59  65     4.64       4.94     5.27   5.61     5.93
66    6.88   6.08   6.78    6.03   6.50    5.90   6.08    5.69   6.23   5.71  66     4.71       5.03     5.38   5.75     6.09
67    7.09   6.24   6.98    6.19   6.65    6.04   6.18    5.79   6.33   5.52  67     4.79       5.13     5.51   5.90     6.27
68    7.31   6.42   7.18    6.36   6.81    6.19   6.28    5.90   6.53   5.97  68     4.87       5.24     5.64   6.06     6.46
69    7.56   6.61   7.40    6.54   6.97    6.34   6.37    6.01   6.69   6.11  69     4.96       5.35     5.78   6.24     6.66

70    7.82   6.81   7.64    6.74   7.14    6.50   6.47    6.12   6.86   6.26  70     5.06       5.47     5.94   6.43     6.87
71    8.09   7.04   7.88    6.95   7.31    6.67   6.55    6.22   7.04   6.42  71     5.16       5.60     6.10   6.63     7.11
72    8.39   7.28   8.14    7.17   7.48    6.84   6.64    6.33   7.23   6.59  72     5.26       5.74     6.28   6.84     7.36
73    8.71   7.54   8.41    7.41   7.65    7.02   6.72    6.44   7.43   6.77  73     5.38       5.89     6.47   7.08     7.62
74    9.05   7.33   8.70    7.67   7.83    7.21   6.80    6.54   7.64   6.97  74     5.50       6.05     6.68   7.33     7.91

75    9.41   8.14   9.00    7.95   8.00    7.40   6.87    6.64   7.86   7.17  75     5.63       6.22     6.90   7.60     8.22
                                                                                                                                 
*Adjusted Age of Annuitant.  M = Male  F = Female
                                                                                                                                 
</TABLE>
<TABLE>
<CAPTION>
Table B above is based on the "1983 Individual Annuitant Mortality Table A" assuming an interest rate of 4% per year compounded
annually.  Settlement rates for any age, or any combination of age and sex not shown above, will be calculated on the same basis as
those rates shown in the table above.  Such rates will be furnished by us upon request.  Amounts shown in the Table below are based
on an assumed interest rate of 4% per year compounded annually.

                                                                                             
Plan E - Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
                                                                                             
        Years          Monthly        Years         Monthly       Years       Monthly
        Payable        Payment        Payable       Payment       Payable     Payment
          <C>         <C>               <C>        <C>              <C>      <C>
           5          $18.32            14         $7.72            23       $5.49
           6           15.56            15          7.34            24        5.35
           7           13.59            16          7.00            25        5.22
           8           12.12            17          6.71            26        5.10
           9           10.97            18          6.44            27        5.00
          10           10.06            19          6.21            28        4.90
          11            9.31            20          6.00            29        4.80
          12            8.69            21          5.81            30        4.72
          13            8.17            22          5.64                                     
</TABLE>
<PAGE>
PAGE 26
DEFERRED ANNUITY CONTRACT

o Flexible purchase payments.
o Optional fixed dollar or variable accumulation values and annuity
  payments.
o Annual payments to begin on the retirement date.
o This contract is nonparticipating.  Dividends are not payable.


IDS Life Insurance Company of New York
Box 5144    
Albany, New York  12205


<PAGE>
PAGE 1
IDS Life Insurance Company of New York
A Stock Company
Box 5144
Albany, New York 12205
An American Express Company

DEFERRED ANNUITY CONTRACT

- - Flexible purchase payments.
- - Optional fixed dollar or variable accumulation values and annuity
  payments.
- - Annuity payments to begin on the retirement date.
- - This contract is nonparticipating.  Dividends are not payable.

Annuitant:          John Doe
Contract Number:    9310-1234567
Contract Date:      April 1, 1986
Retirement Date:    April 1, 2006


This is a deferred annuity contract.  It is a legal contract
between you, as the owner, and us, IDS Life Insurance Company of
New York.  PLEASE READ YOUR CONTRACT CAREFULLY.

If the annuitant is living on the Retirement Date, we will begin to
pay you monthly annuity payments.  Any payments made by us are
subject to the terms of this contract.

We issue this contract in consideration of your application and the
payment of the purchase payments.

Signed for and issued by IDS Life Insurance Company of New York in
Albany, New York, as of the contract date shown above.

ACCUMULATION VALUES AND ANNUITY PAYMENTS, WHEN BASED ON THE
INVESTMENT RESULTS OF THE SEPARATE ACCOUNTS, ARE VARIABLE AND NOT
GUARANTEED AS TO FIXED DOLLAR AMOUNT.

NOTICE OF YOUR RIGHT TO EXAMINE THIS CONTRACT FOR 10 DAYS  If for
any reason you are not satisfied with this contract, return it to
us or our representative within 10 days after you receive it.  We
will then cancel this contract.  Upon such cancellation we will
refund an amount equal to the sum of:  (1) the contract value; and
(2) any premium tax charges paid.  This contract will then be
considered void from its start.

President
/s/ James A. Mitchell

Secretary
/s/ Richard J. O'Brien
<PAGE>
PAGE 2
                   GUIDE TO CONTRACT PROVISIONS

Definitions                   Important words and meanings/Page 3

General Provisions            Entire contract; Incontestability;
                              Misstatement of Age; State Laws;
                              Reports to owner; Evidence of
                              survival; Protection of proceeds;
                              Payments by us; Voting rights/ Page 5

Ownership and Beneficiary     Owner rights; Trust or custodial
                              ownership; Change of ownership;
                              Beneficiary; Change of
                              Beneficiary/Page 5

Payments to Beneficiary       Describes options and amounts payable
                              upon death/Page 6

Purchase Payments             Purchase payments amounts and
                              intervals; Payment limits; Allocation
                              of purchase payments/Page 7

Contract Value                Describes the fixed and variable
                              account contract values; Interest to
                              be credited; Contract administrative
                              charge; Premium taxesl Transfers of
                              contract values/Page 9

Fixed and Variable Accounts   Describes the variable accounts,
                              accumulation units and values; Net
                              investment factor, Mortality and
                              expense risk charge; Annuity unit
                              value/Page 9

Surrender Provisions          Surrender of the contract for its
                              surrender value; Rules for
                              surrender/Page 10

Annuity Provisions            When annuity payments begin;
                              Different ways to receive annuity
                              payments; Determination of payment
                              amounts/Page 12

Table of Settlement Rates     Tables showing the amount of the
                              first variable annuity payment and
                              fixed annuity payments for the
                              various payment plans/Page 14
<PAGE>
PAGE 3
                           CONTRACT DATA

Annuitant:          John Doe
Contract Number:    Sample
Contract Owner:     John Doe
Contract Date:      April 1, 1986
Retirement Date:    April 1, 2006

Upon issuance of this contract your purchase payments have been
scheduled to be paid and applied to the fixed and variable accounts
as shown below.  You may change the amount, frequency and
allocations as provided in this contract.  Refer to the purchase
payments provisions on Page 7.

Lump Sum Single Purchase Payment Only: None
Scheduled Purchase Payments:           Annual Amount:  $1,200
                                       Payable:        $100 monthly

Variable                                      Purchase Payment
Accounts            Mutual Fund               Allocation Percentage
  4         IDS Life Capital Resource Fund            20%
  5         IDS Life Special Income Fund              20%
  6         IDS Life Moneyshare Fund                  20%
  9         IDS Life Managed Fund                     20%

Fixed Account                                         20%

Surrender Charge:  If you surrender all or a portion of this
contract surrender charges may apply.  See Page ____.

Contract Administrative Charge:  See page ____.

Maximum Purchase Payments Permitted

     1st contract year:     $250,000
     each contract year
     thereafter:              50,000

Annuitant:     John Doe          Contract Number:     Sample

Fixed Account
Table of Guaranteed Minimum Contract and Surrender Values
Guaranteed Interest Rate:     4% Per Year Compounded Annually

The following table shows the guaranteed minimum fixed account
contract and surrender values based on these assumptions: (1) $100
purchase payments are received and allocated 100% to the fixed
account at the beginning of each month; (2) There have been no
surrenders; (3) There are no premium tax charges.  If purchase
payments are otherwise paid or allocated or if there are
surrenders, or premium tax charges, the values below will be
adjusted in accordance with the provisions of this contract.
<PAGE>
PAGE 4
                     CONTRACT DATA (continued)

                         Guaranteed                Guaranteed
                         Minimum                   Minimum
End of                   Fixed Account             Fixed Account
Contract Year            Contract Value            Surrender Value

     1                    1201.86                   1118.21
     2                    2451.93                   2284.29
     3                    3752.01                   3500.36
     4                    5104.09                   4768.44
     5                    6510.26                   6090.61
     6                    7972.67                   7469.02
     7                    9493.57                   8989.57
     8                   11075.31                  10571.31
     9                   12720.33                  12216.33
    10                   14431.14                  13927.14
    11                   16210.39                  15706.39
    12                   18060.80                  17556.80
    13                   19985.23                  19481.23
    14                   21986.64                  21482.64
    15                   24068.11                  23564.11
    16                   26232.83                  25728.83
    17                   28484.15                  27980.15
    18                   30825.51                  30321.51
    19                   33260.53                  32756.53
    20                   35792.95                  35288.95
    21                   38426.67                  37922.67
    22                   41165.74                  40661.74
    23                   44014.37                  43510.37
    24                   46976.94                  46472.94
    25                   50058.02                  49554.02
    26                   53262.34                  52758.34
    27                   56594.84                  56090.84
    28                   60060.63                  59556.63
    29                   63665.05                  63161.05
    30                   67413.66                  66909.66

Variable account contract and surrender values are not guaranteed. 
Information concerning contract and surrender values will be
provided to you at any time upon written request.
<PAGE>
PAGE 5
                            DEFINITIONS

The following words are used often in this contract.  When we use
these words, this is what we mean:

annuitant
the person on whose life monthly annuity payments depend.

you, your
The owner of this contract.  The owner may be someone other than
the annuitant.  The owner is shown in the application unless the
owner has been changed as provided in this contract.

we, our, us
IDS Life Insurance Company of New York.

accumulation unit
An accumulation unit is an accounting unit of measure.  It is used
to calculate the contract value prior to settlement.

annuity unit
An annuity unit is an accounting unit of measure.  It is used to
calculate the value of annuity payments from the variable accounts
on and after the retirement date.

contract date
It is the date from which contract anniversaries, contract years,
and contract months are determined.  Your contract date is shown
under Contract Data.

contract anniversary
The same day and month as the contract date each year that the
contract remains in force.

retirement date
The date shown under Contract Data on which annuity payments are to
begin.  This date may be changed as provided in this contract.

settlement
The application of the contract value of this contract to provide
annuity payments.

valuation date
A valuation date is each day the New York Stock Exchange is open
for trading.

valuation period
A valuation period is the interval of time commencing at the close
of business on each valuation date and ending at the close of
business on the next valuation date.

fixed account
The fixed account is made up of all our assets other than those in
any separate account.
<PAGE>
PAGE 6
                      DEFINITIONS (continued)

variable accounts
The variable accounts are named under Contract Data.  Each is a
separate investment account of ours.

fixed annuity
A fixed annuity is an annuity with payments which are guaranteed by
us as to dollar amount during the annuity payment period.

variable annuity
A variable annuity is an annuity with payments which (1) are not
predetermined or guaranteed as to dollar amount; and (2) vary in
amount with the investment experience of one or more of the
variable accounts.

written request
A request in writing signed by you or a Participant and delivered
to us at our home office.
<PAGE>
PAGE 7
                        GENERAL PROVISIONS

Entire Contract

This contract form is and the application form attached to it are
the entire contract between you and us.

No one except one of our corporate officers (President, Vice
President, Secretary or Assistant Secretary) can change or waive
any of our rights or requirements under this contract.  That person
must do so in writing.  None of our representatives or other
persons has the authority to change or waive any of our rights or
requirements under this contract.

In issuing this contract, we have relied upon the application.  The
statements contained in the application are considered
representations and not warranties.  No statement made in
connection with the application will be used by us to void the
contract or to deny a claim unless that statement is part of the
application.

Incontestable

After this contract has been in force during the annuitant's life
for two years from its date of issue, we cannot contest the
contract.

Misstatement of Age or Sex

If the annuitant's birthdate or sex has been misstated, payments
under this contract will be adjusted.  They will be based on what
would have been provided at the correct birthdate and sex.  Any
underpayments made by us will be made up immediately.  Any
overpayments made by us will be subtracted from future payments.

State Laws

This contract is governed by the law of the state in which it is
delivered.  The values and benefits of this contract are at least
equal to those required by such state.

Reports to Owner

At least once a year we will send you a statement showing the
contract value of this contract.  This statement will be based on
any laws or regulations that apply to contracts of this type.

Evidence of Survival

Where any payments under this contract depend on the recipient or
annuitant being alive on a given date, proof that such condition
has been met may be required by us.  Such proof may be required
prior to making the payments.

<PAGE>
PAGE 8
                  GENERAL PROVISIONS (continued)

Protection of Proceeds
Payments under this contract are not assignable by any Beneficiary
prior to the time they are due.  To the extent allowed by law,
payments are not subject to the claims of creditors or to legal
process.

Payments By Us
All sums payable by us are payable at our home office.  Any payment
of a variable annuity or surrender based on the variable contract
value shall be payable only from the variable accounts.

Voting Rights
So long as federal law requires, you may have the right to vote at
the meetings of the Variable Contract Owners.  If you have voting
rights we will send a notice to you telling you the time and place
of a meeting.  The notice will also explain matters to be voted
upon and how many votes you get.

Trustee or custodian owners shall cast votes according to
instructions received from appropriate annuitants.  All other votes
of such trustee or custodian under the same trust or custodial
agreement shall be vast in the same proportion.  If no instructions
are received, the votes may be cast at the trustee's or custodian's
discretion.
<PAGE>
PAGE 9
                     OWNERSHIP AND BENEFICIARY

Owner's Rights
As long as the annuitant is living and unless otherwise provided in
this contract, you may exercise all rights and privileges provided
in this contract or allowed by us.

Trust or Custodial Ownership
If you are a tax qualified trust or tax qualified custodial
account, then your trustees or custodian (or their successors)
properly named by your trust or custodial agreement may exercise
all rights and privileges provided in this contract or allowed by
us.

Change of Ownership (Restricted)
Your right to change the ownership of this contract is restricted. 
This contract may not be sold, assigned, transferred, discounted or
pledged as collateral for a loan or as security for the performance
of an obligation or for any other purpose to any person other than
to us.  However, if you are a trust or a custodian or an employer
as a part of a qualified plan under Sections 401 or 403 or a
deferred compensation plan under Section 457 of the Internal
Revenue Code of 1954, you may transfer ownership of this contract
to the annuitant.  Such transfer must be on a form approved by us. 
The change must be made while the annuitant is living.  Once the
change is received by us, it will take effect as of the date of
your request, subject to any action taken or payment made by us
before the receipt.

Beneficiary
Beneficiaries are those you name, in a form satisfactory to us, to
receive benefits of this contract if you or the annuitant die while
the contract is in force.  The beneficiary is shown in the
application unless you have, since the issue date of this contract,
changed the beneficiary as provided below.

Change of Beneficiary
You may change the beneficiary anytime while the annuitant is
living by satisfactory written request to us.  Once the change is
received by us, it will take effect as of the date of your request,
subject to any action taken or payment made by us before the
receipt.

Only those beneficiaries who are living when death benefits become
payable may share in the benefits, if any.  If no beneficiary is
then living, we will pay the benefits to you, if living, otherwise
to your estate.
<PAGE>
PAGE 10
                      PAYMENTS TO BENEFICIARY

Death Benefit Before the Retirement Date

If the annuitant or owner dies before the retirement date while
this contract is in force we will pay to the beneficiary the
greater of:

1.   the contract value; or

2.   the purchase payments paid less any amounts surrendered.

The above amount will be payable in a lump sum upon the receipt of
due proof of death of the annuitant or owner whichever first
occurs.

In lieu of a lump sum, payment may be made under an Annuity Payment
Plan, provided:

1.   the beneficiary elects the plan within 60 days after we
     receive due proof of death; and

2.   payments begin no later than one year after the date of death;
     and

3.   the plan provides payments over a period which does not exceed
     the life of the beneficiary, or the life expectancy of the
     beneficiary.

In this event, the reference to "annuitant" in the Annuity
Provisions shall apply to the beneficiary.

Any amounts payable or applied by us as described in this section
will be based on the contract value as of the valuation date on or
next following the date on which due proof of death is received at
our Home Office.

Spouse Option to Continue Contract 

If death occurs prior to the retirement date, a spouse who is
designated as sole beneficiary may elect in writing to forego
receipt of the death benefit and instead continue this contract in
force as its owner.  The election by the spouse must be made within
60 days after we receive due proof of death and is subject to the
following:

1.   For contracts that are purchased under plans intended to
     qualify under Sections 403(b) or 457 of the Internal Revenue
     Code of 1954, as amended.  The above option is available only
     if the death benefit becomes payable by reason of the death of
     the owner.

2.   For contracts that are purchased under plans intended to
     qualify under Sections 401(a) of the Internal Revenue Code of
     1954, as amended:  The above option is available only if the
     death benefit becomes payable by reason of the death of the 
<PAGE>
PAGE 11
                PAYMENTS TO BENEFICIARY (continued)

     annuitant prior to age 70-1/2.  In this event the contract may
     be continued in force only until the date on which the
     annuitant would have attained age 70-1/2.

Annuitant's Death After the Retirement Date

If the annuitant dies after the retirement date, the amount
payable, if any, will be as provided in the Annuity Payment Plan
then in effect.
<PAGE>
PAGE 12
                         PURCHASE PAYMENTS

Purchase Payments

Purchase payments are the payments you make for this contract and
the benefits it provides.  Purchase payments must be paid or mailed
to us at our home office or to an authorized agent.  If requested,
we'll give you a receipt for your purchase payments.  Upon payment
to us, purchase payments become our property.

Net purchase payments are that part of your purchase payments
applied to the contract value.  A net purchase payment is equal to
the purchase payment less any applicable premium tax charge.

Amount and Intervals

Purchase payments may be paid in a single sum or in installments
until the earlier of:  (1) the date this contract terminates by
surrender or otherwise; or (2) the date on which annuity payments
begin.

Based upon your application we have scheduled your purchase
payments for the amount and interval as shown under Contract Data. 
Subject to the Payment Limits Provision you may:  (1) stop and/or
restart purchase payments; or (2) increase or decrease the amount
of purchase payments; or (3) change the interval of purchase
payments.

Payment Limits Provision

Maximum Purchase Payments - The maximum purchase payments in the
first or later years may not exceed the amounts shown under
Contract Data.  We reserve the right to increase the maximums.

Minimum Purchase Payments - Upon issue of this contract, a purchase
payment intended as a Single Purchase Payment must be at least
$5,000.  If you intend to make installment purchase payments such
payments, on an annualized basis, must be at least equal to $600.

In addition, except as otherwise provided in this paragraph, the
total purchase payments for any taxable year may not exceed $2,000. 
In the case of a rollover contribution described in Sections 402(a)
(5), 402(a) (7), 403(a) (4), 403(b) (8), 405(d) (3) or, 408(d) (3),
of the Internal Revenue Code of 1954, as amended, there is no limit
on the amount of your purchase payment.  If this contract is
maintained in connection with a Simplified Employee Pension Plan,
employer purchase payments for any taxable year may not exceed 15%
of your compensation or $30,000, whichever is less.  All purchase
payments must be made in cash.  If you die before your entire
interest in this contract has been distributed to you, and your
beneficiary is other than your surviving spouse, no additional
purchase payments will be accepted from your beneficiary under this
contract.

<PAGE>
PAGE 13
                   PURCHASE PAYMENTS (continued)

We also reserve the right to cancel this contract if both of the
following conditions exist at the same time:  (1) no purchase
payments have been paid for a continuous period of 24 months; and
(2) less than $600 in purchase payments have been paid under this
contract.  In this event we will give you 30 days written notice of
our intent to cancel this contract.  Upon such cancellation we will
pay you the contract value in one sum.  This contract will then
terminate.

Allocation of Purchase Payments

You instruct us on how you want your purchase payments allocated
among the fixed account and variable accounts.  Your choice for
each account may be made in any whole percent from 0% to 100% as
long as the total adds upto 100%.  Your allocation instructions as
of the Contract Date are shown in the application.  By written
request, or by another method agreed to by us, you may change your
choice of accounts or percentages.  The first net purchase payment
will be allocated as of the end of the valuation period during
which we make an affirmative decision to issue this contract.  Net
purchase payments after the first will be allocated as of te end of
the valuation period during which we receive the payment at our
home office.
<PAGE>
PAGE 14
                          CONTRACT VALUE

Contract Value

The contract value at any time is the sum of: (1) the Fixed Account
Contract Value; and (2) the Variable Account Contract Value.

If: (1) part or all of the contract value is surrendered; or (2)
charges described herein are made against the contract value; then
a number of accumulation units from the variable accounts and an
amount from the fixed account will be deducted to equal such
amount.  For surrenders, deductions will be made from the fixed or
variable accounts that you specify.  Otherwise, the number of units
from the variable accounts and the amount from the fixed account
will be deducted in the same proportion that your interest in each
bears to the total contract value.

Fixed Account Certificate Value

The fixed account contract value at any time will be: (1) the sum
of all amounts credited to the fixed account under this contract;
less (2) any amounts deducted for charges or surrenders.

Interest to be Credited

We will credit interest to the fixed account contract value. 
Interest will begin to accrue on the date the purchase payments
which are received in our home office become available to us for
use.  Such interest will be credited at rates that we determine
from time to time.  However, we guarantee that the rate will not be
less than the Guaranteed Interest Rate shown under Contract Data.

Variable Account Contract Value

The variable account contract value at any time will be: (1) the
sum of the value of all variable account accumulation units under
this contract resulting from purchase payments so allocated, or
transfers among the variable and fixed accounts; less (2) any units
deducted for charges or surrenders.

Contract Contract Charge

We charge a fee for establishing and maintaining our records for
this contract.  The charge is $6 per quarter and is deducted from
the contract value at the end of each three-month period measured
from the contract date or, if earlier, when the contract is
surrendered.  The charge does not apply after settlement of this
contract.

Premium Tax Charges

A charge will be made by us against the contract value of this
contract at the time that any premium taxes not previously deducted
are payable.
<PAGE>
PAGE 15
                    CONTRACT VALUE (continued)

Transfers of Certificate Values

While this contract is in force prior to the settlement date,
transfer of contract values may be made as outlined below:

1.   You may transfer all or a part of the values held in one or
     more of the variable accounts to another one or more of the
     variable accounts.  Subject to item 2, you may also transfer
     values held in one or more of the variable accounts to the
     fixed account.

2.   On or within the 30 days after a contract anniversary you may
     transfer values from the fixed account to one of more of the
     variable accounts.  Only one such transfer is allowed during
     this period each year.  If such a transfer is made, no
     transfers from a variable account to the fixed account may be
     made until the next contract anniversary.

You may make a transfer by written request.  Transfer requests may
also be made by telephone if we have received a properly completed
authorization form.  There is no fee or charge for these transfers. 
However, the minimum transfer amount is $250, or if less, the
entire value in the account from which the transfer is being made. 
This transfer privilege may be suspended or modified by us at any
time.
<PAGE>
PAGE 16
                    FIXED AND VARIABLE ACCOUNTS

The Fixed Account

The fixed account is our general account.  It is made up of all of
our assets other than: (1) those in the variable accounts; and (2)
those in any other segregated asset account.

The Variable Accounts

The variable accounts are separate investment accounts of ours. 
They are named under Contract Data.  We have allocated a part of
our assets for this and certain other contracts to the variable
accounts.  Such assets remain our property.  However, they may not
be charged with the liabilities from any other business in which we
may take part.

Investments of the Variable Accounts

Purchase payments applied to the variable accounts will be
allocated as specified in your application for this contract or as
later changed.  Each variable account will buy, at net asset value,
shares of the fund shown for that account under Contract Data or as
later added or changed.

Valuation of Assets

Mutual fund shares in the variable accounts will be valued at their
net asset value.

Variable Account Accumulation Units

The number of accumulation units for each of the variable accounts
is found by dividing: (1) the net amount allocated to the account;
by (2) the accumulation unit value for the account for the
valuation period during which we received the purchase payment.

Variable Account Accumulation Unit Value

The value of an accumulation unit for each of the variable accounts
was arbitrarily set at $1 when the first mutual fund shares were
bought.  The value for any later valuation period is found as
follows:

     The accumulation unit value for each variable account for the
     last prior valuation period is multiplied by the net
     investment factor for the same account for the next following
     valuation period.  The result is the accumulation unit value. 
     The value of an accumulation unit may increase or decrease
     from one valuation period to the next.

<PAGE>
PAGE 17
              FIXED AND VARIABLE ACCOUNTS (continued)

Net Investment Factor

The net investment factor is an index applied to measure the
investment performance of a variable account from one valuation
period to the next.  The net investment factor may be greater or
less than one; therefore, the value of an accumulation unit may
increase or decrease.

The net investment factor for any such account for any valuation
period is determined by: dividing (1) by (2) and subtracting (3)
from the result.  This is done where:

(1) is the sum of:

     a.   the net asset value per share of the mutual fund held in
          the variable account determined at the end of the current
          valuation period; plus

     b.   the per share amount of any dividend or capital gain
          distributions made by the mutual fund held in the
          variable account, if the "ex-dividend" date occurs during
          the current valuation period.

(2)  is the net asset value per share of the mutual fund held in
     the variable account, determined at the end of the last prior
     valuation period.

(3)  is a factor representing the mortality and expense risk
     charge.

Mortality and Expense Risk Charge

In calculating accumulation unit values we will deduct a mortality
and expense risk charge from the variable accounts equal, on an
annual basis, to 1.00% of the daily net asset value.  This
deduction is made to compensate us for assuming the mortality and
expense risks under contracts of this type.  The deduction is: (1)
made from each variable account; and (2) computed on a daily basis.

Annuity Unit Value

The value of an annuity unit for each variable account was
arbitrarily set at $1 when the first mutual funds were bought.  The
value for any later valuation period is found as follows:

1.   The annuity unit for each variable account for the last prior
     valuation period is multiplied by the net investment factor
     for the account for the valuation period for which the annuity
     unit value is being calculated.

2.   The result is multiplied by an interest factor.  This is done
     to neutralize the assumed investment rate which is built into
     the annuity tables on page 14.
<PAGE>
PAGE 18
                       SURRENDER PROVISIONS

Surrender

By written request and subject to the rules below you may:

1.   surrender this contract for the total surrender value; or

2.   partially surrender this contract for a part of the surrender
     value.

Surrender Value

The surrender value at any time will be:

1.   the contract value;

2.   minus the contract administrative charge;

3.   minus any surrender charge.

Surrender Charge

In order to determine if a surrender charge applies to a partial or
total surrender we first divide the contract value into three
parts.

1.   Contract Earnings - This is the contract value minus the sum
     of all purchase payments we have received that have not been
     previously surrendered.

2.   Old Purchase Payments - These are purchase payments we
     received in any contract year more than five years prior to
     the contract year of surrender.

3.   New Purchase Payments - These are purchase payments we
     received during the contract year in which the surrender is
     made or in the five immediately preceding the contract years.

We will then surrender your contract value in the following order
so that the amount surrendered, less any surrender charge that
applies, equals your requested surrender amount:

1.   Contract Earnings, if any, are surrendered first.  There is no
     surrender charge on contract earnings.

2.   Next, if necessary, we surrender Old Purchase Payments not
     previously surrendered.  There is no surrender charge on Old
     Purchase Payments.

3.   Finally, if necessary, we surrender New Purchase Payments not
     previously surrendered.  There is a surrender charge of 7%
     applied to New Purchase Payments surrendered.
<PAGE>
PAGE 19
                 SURRENDER PROVISIONS (continued)

Surrender Charge Calculation

The surrender charge for a total surrender is calculated by
multiplying the amount representing new purchase payments by .07.

The surrender charge for a partial surrender is calculated by
dividing the surrender amount requested representing "new purchase
payments" by .93 and multiplying the result by .07.

For example, the surrender charge on a $1,000 partial surrender
request (representing all "new purchase payments") would be $75.27,
resulting from the following calculation:  ($1,000/.93 x .07 =
75.27

Rules for Surrender

All surrenders will have the following conditions:

1.   You must apply by written request:  (a) while this contract is
     in force; and (b) prior to the earlier of the retirement date
     or the death of the annuitant.

2.   You must surrender an amount equal to at least $250.  The
     contract value after a partial surrender must be at least
     $600.

3.   The amount surrendered, less any charges, will normally be
     paid to you within seven days of the receipt of written
     request and this contract, if required.  For surrenders from
     the fixed account, we have the right to defer payment to you
     for up to 6 months from the date we receive the request.

4.   For partial surrenders, if you do not specify from which
     accounts the surrender is to be made, the surrender will be
     made from the variable accounts and fixed account in the same
     proportion as the your interest in each bears to the contract
     value.

5.   Any amounts surrendered and charges which may apply can not be
     repaid.

Upon surrender for the full surrender value this contract will
terminate.  We may require that you return the contract to us
before we pay the full surrender value.

Suspension or Delay in Payment of Surrender

We have the right to suspend or delay the date of any surrender
payment from the variable accounts for any period:

1.   When the New York Stock Exchange is closed; or

2.   When trading on the New York Stock Exchange is restricted; or
<PAGE>
PAGE 20
                 SURRENDER PROVISIONS (continued)

3.   When an emergency exists as a result of which: (a) disposal of
     securities held in the variable accounts is not reasonably
     practicable; or (b) it is not reasonably practicable to fairly
     determine the value of the net assets of the variable account;
     or

4.   During any other period when the Securities and Exchange
     Commission, by order, so permits for the protection of
     security holders.

Rules and regulations of the Securities and Exchange Commission
will govern as to whether the conditions set forth in 2 and 3
exist.
<PAGE>
PAGE 21
                        ANNUITY PROVISIONS

Settlement

When settlement occurs, the contract value will be applied to make
annuity payments.  The first payment will be made as of the
retirement date.  This date is shown under Contract Data.  Before
payments begin we will require satisfactory proof that the
annuitant is alive.  We may also require that you exchange this
contract for a supplemental contract which provides the annuity
payments.

Change of Retirement Date

You may change the retirement date shown for this contract.  Tell
us the new date by written request.  However, the retirement date
must not be later than the annuitant's 75th birthday.  Also, if you
select a new date, it must be at least 30 days after we receive
your written request at our home office.

Annuity Payment Plans

Subject to the terms of this contract, annuity payments may be made
on a fixed-dollar basis, a variable basis or a combination of both. 
You can schedule receipt of annuity payment according to one of the
Plans A through E below or another plan agreed to by us provided:

1.   the Plan selected provides for payments over the life of the
     annuitant or over the life of the annuitant and a joint
     annuitant; or

2.   the Plan selected provides for payments over a period which
     does not exceed the life expectancy of the annuitant, or over
     the life expectancy of the annuitant and a joint annuitant.

Plan A - This provides monthly annuity payments during the lifetime
of the annuitant.  No payments will be made after the annuitant
dies.

Plan B - This provides monthly annuity payments during the lifetime
of the annuitant with a guarantee by us that payments will be made
for a period of at least five, ten or fifteen years.  You must
select the guaranteed period.

Plan C - This provides monthly annuity payments during the lifetime
of the annuitant with a guarantee by us that payments will be made
for a certain number of months.  We determine the number of months
by dividing the amount applied under this Plan by the amount of the
first monthly annuity payment.

Plan D - Monthly payments will be paid during the lifetime of the
annuitant and a joint annuitant.  When either the annuitant or the
joint annuitant dies we will continue to make monthly payments
during the lifetime of the survivor.  No payments will be paid
after the death of both the annuitant and joint annuitant.
<PAGE>
PAGE 22
                  ANNUITY PROVISIONS (continued)

Plan E - This provides monthly fixed dollar annuity payments for a
period of years.  The period of years may be no less than 5 nor
more than 30.

By written request to us at least 30 days before the Retirement
Date, you may select the Plan.  If at least 30 days before the
Retirement Date we have not received at our home office your
written request to select a Plan, we will make payments according
to Plan B with payments guaranteed for ten years.

If the amount to be applied to a Plan would not provide an initial
monthly payment of at least $20, we have the right to make a lump
sum payment of the contract value.

Fixed Annuity

A fixed annuity is an annuity with payments that are guaranteed by
us as to dollar amount.  Fixed annuity payments after the first
payment will never be less than the amount of the first payment. 
At settlement, the fixed account contract value will be applied to
the applicable Annuity Table.  This will be done in accordance with
the Payment Plan chosen.  The amount payable for each $1,000 so
applied is shown in Table B on page 15.

Variable Annuity

A variable annuity is an annuity with payments which: (1) are not
predetermined or guaranteed as to dollar amount; and (2) vary in
amount with the investment experience of the variable accounts.

Determination of First Variable Annuity Payment

At settlement, the variable account contract value will be applied
to the applicable Annuity Table.  This will be done: (1) on the
valuation date on or next preceding the seventh calendar day before
the retirement date; and (2) in accordance with the Payment Plan
chosen.  The amount payable for the first payment for each $1,000
so applied is shown in Table A on page 14.

Variable Annuity Payments After the First Payment

Variable annuity payments after the first payment vary in amount. 
The amount changes with the investment performance of the variable
accounts.  The dollar amount of variable annuity payments after the
first is not fixed.  It may change from month to month.  The dollar
amount of such payments is determined as follows:

1.   The dollar amount of the first annuity payment is divided by
     the value of an annuity unit as of the valuation date on or
     next preceding the seventh calendar day before the retirement
     date.  This result establishes the fixed number of annuity
     units for each monthly annuity payment after the first
     payment.  This result established the fixed number of annuity
<PAGE>
PAGE 23
                  ANNUITY PROVISIONS (continued)

     units for each monthly annuity payment after the first
     payment.  This number of annuity units remains fixed during
     the annuity payment period.

2.   The fixed number of annuity units is multiplied by the annuity
     unit value as of the valuation date on or next preceding the
     seventh calendar day before the date the payment is due.  This
     result establishes the dollar amount of the payment.

We guarantee that the dollar amount of each payment after the first
will not be affected by variations in expenses or mortality
experience.

Exchange of Annuity Units

Annuity units of any variable account may be exchanged for units of
any of the other variable accounts.  This may be done no more than
once a year.  Once annuity payments start no exchanges may be made
to or from any fixed annuity.
<PAGE>
PAGE 24
                     TABLE OF SETTLEMENT RATES

Table A below shows the amounf of the first monthly variable
annuity payment, based on a 3-1/2% assumed investment return, for
each $1,000 of value applied under any Payment Plan.  The amount of
the first and all subsequent monthly fixed dollar annuity payments
for each $1,000 of value applied under any Payment Plan will be
based on our fixed dollar Table of Settlement Rates in effect on
the settlement dae.  Such rates are guaranteed to be not less than
those shown in Table B.  The amount of such annuity payments under
Plans A, B, and C will depend upon the sex and the adjusted age of
the annuitant on the date of settlement.  The amount of such
annuity payments under Plan D will depend upon the sex and the
adjusted age of the annuitant and joint annuitant on the date of
settlement.  Adjusted age shall be equal to the age nearest
birthday minus an "adjustment" depending on the calendar year of
birth of the annuitant as follows:

Calendar Year of                   Calendar Year of
Annuitant's Birth   Adjustment     Annuitant's Birth    Adjustment
Prior to 1920           0          1945 through 1949        6
1920 through 1924       1          1950 through 1959        7
1925 through 1929       2          1960 through 1969        8
1930 through 1934       3          1970 through 1979        9
1935 through 1939       4          1980 through 1989       10
1940 through 1944       5          After 1989              11

<PAGE>
PAGE 25
<TABLE>
<CAPTION>
               TABLE OF SETTLEMENT RATES (continued)

TABLE A  Amount of Each Monthly Annuity Payment Per $1,000 Applied                                                               

         Plan A                              Plan B                     Plan C                                                   
      Life          5 Years        10 Years       15 Years       With         Adj.      Adjusted Age of Female Joint Annuitant   
Adj.  Income        Certain        Certain        Certain        Refund       Male   10 Years   5 Years  Same   5 Years  10 Years
Age*  M      F      M       F      M       F      M       F      M      F     Age*   Younger    Younger  Age    Older    Older   
<C>   <C>    <C>    <C>     <C>    <C>     <C>    <C>     <C>    <C>    <C>   <C>    <C>        <C>      <C>    <C>      <C>
40    3.96   3.73   3.96    3.73   3.94    3.72   3.92    3.71   3.88   3.69  40     3.37       3.45     3.53   3.61     3.69
41    4.01   3.76   4.00    3.76   3.99    3.76   3.97    3.75   3.92   3.72  41     3.39       3.47     3.56   3.65     3.73
42    4.06   3.80   4.05    3.80   4.04    3.80   4.01    3.78   3.97   3.76  42     3.41       3.50     3.59   3.68     3.77
43    4.11   3.84   4.11    3.84   4.09    3.84   4.06    3.82   4.01   3.80  43     3.43       3.52     3.62   3.72     3.81
44    4.17   3.89   4.16    3.88   4.14    3.88   4.11    3.86   4.06   3.83  44     3.45       3.55     3.65   3.76     3.85

45    4.22   3.93   4.22    3.93   4.20    3.92   4.16    3.91   4.11   3.87  45     3.48       3.58     3.69   3.80     3.89
46    4.29   3.98   4.28    3.98   4.25    3.97   4.21    3.95   4.16   3.92  46     3.51       3.61     3.73   3.84     3.94
47    4.35   4.03   4.34    4.03   4.31    4.02   4.27    4.00   4.21   3.96  47     3.53       3.64     3.76   3.88     3.99
48    4.42   4.08   4.41    4.08   4.38    4.07   4.33    4.05   4.26   4.01  48     3.56       3.68     3.80   3.93     4.05
49    4.49   4.14   4.48    4.13   4.44    4.12   4.39    4.10   4.32   4.06  49     3.59       3.72     3.85   3.98     4.10

50    4.56   4.20   4.55    4.19   4.51    4.18   4.45    4.15   4.38   4.11  50     3.62       3.75     3.89   4.03     4.16
51    4.64   4.26   4.62    4.25   4.58    4.24   4.52    4.21   4.45   4.16  51     3.65       3.79     3.94   4.09     4.22
52    4.72   4.32   4.70    4.32   4.66    4.30   4.58    4.26   4.51   4.22  52     3.69       3.83     3.99   4.14     4.29
53    4.80   4.39   4.79    4.38   4.74    4.36   4.65    4.33   4.58   4.27  53     3.73       3.88     4.04   4.21     4.36
54    4.89   4.46   4.88    4.46   4.82    4.43   4.73    4.39   4.66   4.34  54     3.76       3.93     4.10   4.27     4.43

55    4.99   4.54   4.97    4.53   4.91    4.51   4.80    4.46   4.73   4.40  55     3.80       3.97     4.16   4.34     4.51
56    5.09   4.62   5.07    4.61   5.00    4.58   4.88    4.53   4.81   4.47  56     3.85       4.03     4.22   4.41     4.59
57    5.20   4.71   5.17    4.70   5.10    4.66   4.97    4.60   4.90   4.54  57     3.89       4.08     4.29   4.49     4.68
58    5.32   4.80   5.29    4.79   5.20    4.75   5.05    4.68   4.99   4.62  58     3.94       4.14     4.36   4.57     4.78
59    5.44   4.90   5.41    4.88   5.31    4.84   5.14    4.76   5.08   4.70  59     3.99       4.20     4.43   4.66     4.88

60    5.57   5.00   5.53    4.99   5.42    4.93   5.23    4.84   5.18   4.78  60     4.04       4.27     4.51   4.76     4.99
61    5.71   5.11   5.67    5.09   5.54    5.03   5.33    4.93   5.29   4.87  61     4.10       4.34     4.59   4.86     5.10
62    5.86   5.23   5.81    5.21   5.67    5.14   5.42    5.02   5.40   4.96  62     4.16       4.41     4.68   4.97     5.23
63    6.02   5.36   5.97    5.33   5.80    5.25   5.52    5.12   5.51   5.06  63     4.22       4.49     4.78   5.08     5.36
64    6.20   5.49   6.13    5.46   5.94    5.37   5.62    5.21   5.63   5.17  64     4.28       4.57     4.88   5.20     5.50

65    6.38   5.64   6.31    5.60   6.08    5.50   5.72    5.31   5.76   5.28  65     4.35       4.66     4.99   5.34     5.66
66    6.58   5.79   6.49    5.75   6.23    5.63   5.82    5.42   5.90   5.39  66     4.43       4.75     5.11   5.48     5.82
67    6.79   5.95   6.69    5.91   6.38    5.77   5.92    5.53   6.04   5.52  67     4.51       4.85     5.24   5.63     6.00
68    7.02   6.13   6.90    6.08   6.54    5.91   6.02    5.63   6.19   5.65  68     4.59       4.96     5.37   5.79     6.19
69    7.26   6.32   7.12    6.26   6.71    6.07   6.12    5.74   6.35   5.79  69     4.68       5.07     5.51   5.97     6.39

70    7.52   6.53   7.35    6.46   6.87    6.23   6.21    5.86   6.52   5.94  70     4.78       5.20     5.67   6.16     6.60
71    7.80   6.75   7.60    6.67   7.05    6.40   6.30    5.97   6.69   6.09  71     4.88       5.33     5.83   6.36     6.84
72    8.09   6.99   7.86    6.89   7.22    6.58   6.39    6.08   6.88   6.26  72     4.98       5.47     6.01   6.58     7.09
73    8.41   7.26   8.13    7.13   7.40    6.76   6.47    6.18   7.07   6.44  73     5.10       5.62     6.20   6.81     7.35
74    8.75   7.54   8.42    7.39   7.57    6.95   6.55    6.29   7.27   6.63  74     5.22       5.78     6.41   7.06     7.64

75    9.12   7.85   8.72    7.67   7.75    7.14   6.62    6.39   7.49   6.83  75     5.35       5.95     6.63   7.33     7.95
                                                                                                                                 
*Adjusted Age of annuitant.  M = *Adjusted age of annuitant.  M = Male    F = Female
                                                                                                                                 
Table A above is based on the "1983 Individual Annuitant Mortality Table A."  Settlement rates for any age, or any combination of
age and sex not shown above, will be calculated on the same basis as those rates shown in the table above.  Such rates will be
furnished by us upon request.
</TABLE>
<PAGE>
PAGE 26
<TABLE>
<CAPTION>
                              TABLE OF SETTLEMENT RATES (continued)

TABLE B Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied                                            
         Plan A                              Plan B                     Plan C                                                   
      Life          5 Years        10 Years       15 Years       With         Adj.    Adjusted Age of Female Joint Annuitant
Adj.  Income        Certain        Certain        Certain        Refund       Male   10 Years   5 Years  Same   5 Years  10 Years
Age*  M      F      M       F      M       F      M       F      M      F     Age*   Younger    Younger  Age    Older    Older   
<C>   <C>    <C>    <C>     <C>    <C>     <C>    <C>     <C>    <C>    <C>   <C>    <C>        <C>      <C>    <C>      <C>
40    4.27   4.04   4.26    4.04   4.25    4.03   4.23    4.02   4.20   4.01  40     3.69       3.76     3.84   3.92     4.00
41    4.31   4.07   4.31    4.07   4.30    4.07   4.27    4.06   4.24   4.04  41     3.71       3.79     3.87   3.95     4.03
42    4.36   4.11   4.36    4.11   4.34    4.10   4.32    4.09   4.28   4.07  42     3.73       3.81     3.90   3.99     4.07
43    4.42   4.15   4.41    4.15   4.39    4.14   4.36    4.13   4.32   4.11  43     3.75       3.84     3.93   4.02     4.11
44    4.47   4.19   4.46    4.19   4.44    4.18   4.41    4.17   4.37   4.15  44     3.77       3.86     3.96   4.06     4.15

45    4.53   4.24   4.54    4.23   4.50    4.23   4.46    4.21   4.42   4.19  45     3.80       3.89     3.99   4.10     4.19
46    4.59   4.28   4.58    4.28   4.55    4.27   4.51    4.25   4.47   4.23  46     3.82       3.92     4.03   4.14     4.24
47    4.65   4.33   4.64    4.33   4.61    4.32   4.56    4.30   4.52   4.27  47     3.85       3.95     4.07   4.18     4.29
48    4.72   4.38   4.71    4.38   4.67    4.37   4.62    4.34   4.58   4.32  48     3.87       3.98     4.10   4.22     4.34
49    4.79   4.44   4.77    4.43   4.74    4.42   4.68    4.39   4.63   4.36  49     3.90       4.02     4.15   4.27     4.39

50    4.86   4.50   4.85    4.49   4.81    4.47   4.74    4.45   4.69   4.41  50     3.93       4.06     4.19   4.32     4.45
51    4.94   4.56   4.92    4.55   4.88    4.53   4.80    4.50   4.76   4.47  51     3.96       4.09     4.23   4.38     4.51
52    5.02   4.62   5.00    4.61   4.95    4.59   4.87    4.56   4.82   4.52  52     4.00       4.13     4.28   4.43     4.57
53    5.10   4.69   5.08    4.68   5.03    4.66   4.94    4.62   4.90   4.58  53     4.03       4.18     4.33   4.49     4.64
54    5.19   4.76   5.17    4.75   5.11    4.72   5.01    4.68   4.97   4.64  54     4.07       4.22     4.39   4.56     4.72

55    5.29   4.84   5.26    4.83   5.20    4.80   5.09    4.74   5.05   4.71  55     4.11       4.27     4.45   4.62     4.79
56    5.39   4.92   5.36    4.91   5.29    4.87   5.17    4.81   5.13   4.77  56     4.15       4.32     4.51   4.70     4.88
57    5.49   5.00   5.47    4.99   5.38    4.95   5.25    4.88   5.21   4.85  57     4.19       4.37     4.57   4.77     4.96
58    5.61   5.09   5.58    5.08   5.48    5.03   5.33    4.96   5.30   4.92  58     4.24       4.43     4.64   4.85     5.06
59    5.73   5.19   5.70    5.17   5.59    5.12   5.42    5.04   5.40   5.00  59     4.28       4.49     4.71   4.94     5.16

60    5.86   5.29   5.82    5.27   5.70    5.22   5.51    5.12   5.50   5.09  60     4.34       4.55     4.79   5.03     5.27
61    6.00   5.40   5.96    5.38   5.82    5.32   5.60    5.21   5.60   5.18  61     4.39       4.62     4.87   5.13     5.38
62    6.16   5.52   6.10    5.50   5.95    5.42   5.69    5.30   5.72   5.27  62     4.45       4.69     4.96   5.24     5.50
63    6.32   5.65   6.26    5.62   6.08    5.53   5.79    5.39   5.83   5.37  63     4.51       4.77     5.06   5.35     5.64
64    6.49   5.78   6.42    5.75   6.21    5.65   5.89    5.49   5.96   5.48  64     4.57       4.85     5.16   5.48     5.78

65    6.68   5.92   6.60    5.89   6.35    5.77   5.98    5.58   6.09   5.59  65     4.64       4.94     5.27   5.61     5.93
66    6.88   6.08   6.78    6.03   6.50    5.90   6.08    5.69   6.23   5.71  66     4.71       5.03     5.38   5.75     6.09
67    7.09   6.24   6.98    6.19   6.65    6.04   6.18    5.79   6.33   5.52  67     4.79       5.13     5.51   5.90     6.27
68    7.31   6.42   7.18    6.36   6.81    6.19   6.28    5.90   6.53   5.97  68     4.87       5.24     5.64   6.06     6.46
69    7.56   6.61   7.40    6.54   6.97    6.34   6.37    6.01   6.69   6.11  69     4.96       5.35     5.78   6.24     6.66

70    7.82   6.81   7.64    6.74   7.14    6.50   6.47    6.12   6.86   6.26  70     5.06       5.47     5.94   6.43     6.87
71    8.09   7.04   7.88    6.95   7.31    6.67   6.55    6.22   7.04   6.42  71     5.16       5.60     6.10   6.63     7.11
72    8.39   7.28   8.14    7.17   7.48    6.84   6.64    6.33   7.23   6.59  72     5.26       5.74     6.28   6.84     7.36
73    8.71   7.54   8.41    7.41   7.65    7.02   6.72    6.44   7.43   6.77  73     5.38       5.89     6.47   7.08     7.62
74    9.05   7.33   8.70    7.67   7.83    7.21   6.80    6.54   7.64   6.97  74     5.50       6.05     6.68   7.33     7.91

75    9.41   8.14   9.00    7.95   8.00    7.40   6.87    6.64   7.86   7.17  75     5.63        6.22     6.90   7.60     8.22
                                                                                                                                 
*Adjusted Age of Annuitant.   M = Male  F = Female
                                                                                                                                 
Table B above is based on the "1983 Individual Annuitant Mortality Table A" assuming an interest rate of 4% per year compounded
annually.  Settlement rates for any age, or any combination of age and sex not shown above, will be calculated on the same basis as
those rates shown in the table above.  Such rates will be furnished by us upon request.  Amounts shown in the Table below are based
on an assumed interest rate of 4% per year compounded annually.
</TABLE>
<TABLE>
<CAPTION>
                                                                                             
Plan E - Dollar Amount of Each Monthly Fixed Dollar Annuity Payment Per $1,000 Applied
                                                                                             
        Years       Monthly      Years       Monthly     Years       Monthly
        Payable     Payment      Payable     Payment     Payable     Payment
          <C>      <C>             <C>      <C>            <C>      <C>
           5       $18.32          14       $7.72          23       $5.49
           6        15.56          15        7.34          24        5.35
           7        13.59          16        7.00          25        5.22
           8        12.12          17        6.71          26        5.10
           9        10.97          18        6.44          27        5.00
          10        10.06          19        6.21          28        4.90
          11         9.31          20        6.00          29        4.80
          12         8.69          21        5.81          30        4.72
          13         8.17          22        5.64                                            
</TABLE>
<PAGE>
PAGE 27
DEFERRED ANNUITY CONTRACT

o Flexible purchase payments.
o Optional fixed dollar or variable accumulation values and annuity
  payments.
o Annual payments to begin on the retirement date.
o This contract is nonparticipating.  Dividends are not payable.


IDS Life Insurance Company of New York
Box 5144    
Albany, New York  12205


<PAGE>
PAGE 1
REVISED CHARTER OF IDS LIFE INSURANCE COMPANY OF NEW YORK

Revised As Of April, 1992


     WE, the undersigned, all being natural persons of full age,
and at least two-thirds of us citizens of the United States, and at
least three (3) of us being residents of the State of New York, do
hereby declare our intention to form a stock corporation for the
purpose of doing the kinds of insurance business authorized by
Paragraphs "1", "2", and "3", respectively, of Section 1113 of the
Insurance Law of the State of New York, and for that purpose do
hereby adopt the following charter:

CHARTER

ARTICLE I

The name of this Corporation shall be:

IDS LIFE INSURANCE COMPANY OF NEW YORK

ARTICLE II

     The principal office of this Corporation shall be located in
the County of Albany in the State of New York.

ARTICLE III

     SECTION 1.  The kind or kinds of insurance to be transacted by
the Corporation are those kinds specified in Paragraphs "1", "2",
and "3", Section 1113, of Article IV of the Insurance Law of the
State of New York, as follows:
     1.   Life insurance," meaning every insurance upon the lives
of human beings and every insurance appertaining thereto.  The
business of life insurance shall be deemed to include the granting
of endowments benefits; additional benefits in the event of death
by accident or accidental means; additional benefits operating to
safeguard the contract from lapse, or to provide a special
surrender value, in the event of total and permanent disability of
the insured; and optional modes of settlement of proceeds.  Amounts
paid to the Corporation for life insurance and proceeds applied
under optional modes of settlement or under dividend options may be
allocated by the Corporation to one or more separate accounts
pursuant to Section 4240.
     2.   "Annuities," meaning all agreements to make periodical
payments where the making or continuance of all or of some of a
series of such payments, or the amount of any such payment, is
dependent upon the continuance of human life, except payments made
under the authority of paragraph one.  Amounts paid to the
Corporation to provide annuities and proceeds applied under
optional modes of settlement or under dividend options may be
allocated by the Corporation to one or more separate accounts
pursuant to Section 4240.
<PAGE>
PAGE 2
     3.   "Accident and health insurance," meaning (a) insurance
against death or personal injury by accident or by any specified
kind or kinds of accident and insurance against sickness, ailment
or bodily injury, including insurance providing disability benefits
pursuant to article nine of the workmen's compensation law, except
as specified in subparagraph (b) following; and (b) Non-cancelable
disability insurance, meaning insurance against disability
resulting from sickness, ailment or bodily injury (but not
including insurance solely against accidental injury) under any
contract which does not give the insurer the option to cancel or
otherwise terminate the contract at or after one year from its
effective date or renewal date.
     SECTION 2.  The Corporation may also engage in the reinsurance
of the kinds of insurance business it is authorized to do.
     SECTION 3.  The foregoing enumeration of specific kinds of
insurance shall not be held to limit or restrict the powers of the
Corporation to carry on any other business to the extent
necessarily or properly incidental to such kinds of insurance.
     SECTION 4.  The Corporation shall have full power and
authority to cede and assume reinsurance of any risks subject to
the Insurance Law and the rules and regulations of the Insurance
Department of the State of New York.
     SECTION 5.  The Corporation shall have and may exercise such
other powers as are conferred upon it by law.

ARTICLE IV

     The mode and manner in which the corporate powers of the
Corporation shall be exercised is through a Board of Directors and
through such Committees of the Board of Directors, officers and
agents as such Board and the By-Laws of the Corporation shall
empower.

ARTICLE V

     SECTION 1.  The number of the directors of the Corporation
shall be not less than thirteen (13) nor more than twenty-three
(23) and shall be determined by the provisions of the By-Laws.  In
no case shall the number of directors be less than thirteen (13). 
In no case shall a decrease in the number of directors shorten the
term of any incumbent director.
     SECTION 2.  The directors shall be elected at each annual
meeting of the stockholders of the Corporation, and the directors
so elected shall hold office for one year and until their
respective successors shall have been elected and shall have
qualified.  The directors shall be chosen and elected by a
plurality of the whole number of shares voted.
     SECTION 3.  Any director may be removed with or without cause
by the majority vote of the stockholders present in person or by
proxy at any meeting of stockholders.  Not less than one-third of
the directors may call a Special Meeting for the purpose of
removing any director for cause and at such Special Meeting so
called, such director may be removed by the affirmative vote of
two-thirds of the remaining directors.
<PAGE>
PAGE 3
     SECTION 4.  Whenever any vacancy in the Board of Directors
shall occur by death, resignation, removal or otherwise, and
whenever the number of directors is increased, such vacancy may be
filled and such additional directors may be elected, for the
remainder of the term in which such event shall happen, by a
majority vote of the directors then in office in such manner as may
be prescribed by the By-Laws.
     SECTION 5.  If the directors shall not be elected in any year
at the annual meeting of stockholders as hereinabove provided, or
if, because of a vacancy or vacancies on the Board of Directors,
the Number of the Board shall be less than thirteen (13), the
Corporation shall not for that reason be dissolved, but every
director shall continue to hold office and discharge his duties
until his successor shall have been elected.
     SECTION 6.  At all times a majority of the directors shall be
citizens and residents of the State of New York or of adjoining
states, not less than three (3) thereof shall be residents of the
State of New York, and each director shall be at least twenty-one
(21) years of age.

ARTICLE VI

INDEMNIFICATION OF CORPORATION PERSONNEL

     To the extent permitted and in the manner prescribed by law,
the Corporation shall indemnify any person made, or threatened to
be made, a party to any action, suit or proceeding, civil or
criminal, by reason of the fact that he, his testator or intestate,
is or was Director or Officer of the Corporation or of any other
corporation of any type or kind, domestic or foreign, which he
served in any capacity at the request of the Corporation, against
judgements, fines, amounts paid in settlement and reasonable
expenses (which the Corporation may advance), including attorneys'
fees, actually and necessarily incurred as a result of such action,
suit or proceeding, or any appeal therein.  The foregoing right of
indemnification shall not be exclusive of any other right to which
any such person may be entitled.  Neither the adoption of this
resolution nor any modification or repeal hereof, or of any
provision of any applicable law shall, unless otherwise required by
law, enlarge or diminish any right of indemnification of a Director
or Officer as it existed at the time of accrual of the alleged
cause of action asserted in the threatened or pending action, suit
or proceeding in which the expenses were incurred or other amount
was paid.

INDEMNIFICATION OF OTHER PERSONNEL

     The Board, in its discretion, may authorize the Corporation to
indemnify any person, other than a Director or Officer, for
expenses incurred or other amounts paid in any civil or criminal
action, suit or proceeding, to which such person was, or was
threatened to be, made a party by reason of the fact that he, his
testator or intestate, is or was an employee or agent of the
Corporation or of any other corporation of any type or kind,
domestic or foreign, which he served in any capacity at the request
of the Corporation, against judgements, fines, amounts paid in 
<PAGE>
PAGE 4
settlement and reasonable expenses (which the Corporation may
advance), including attorney's fees, actually and necessarily
incurred as a result of such action, suit or proceeding, or any
appeal therein.

ARTICLE VII

     Except as otherwise provided by law, the presence in person or
by proxy at any meeting of stockholders of the holders of a
majority of shares of the capital stock of the Corporation issued
and outstanding and entitled to vote thereat shall constitute a
quorum.  If, however, such majority shall not be represented at any
meeting of the stockholders, the holders of a majority of the
shares present or represented and entitled to vote thereat shall
have power to adjourn the meeting from time to time without notice
until the requisite amount of shares entitled to vote at such
meeting shall be represented.  At such adjourned meeting at which
the requisite number of shares entitled to vote thereat shall be
represented, any business may be transacted which might have been
transacted at the meeting as originally notified.

ARTICLE VIII

     The names and post office residence addresses of the
directors, who shall serve until the first annual meeting of the
Corporation, are as follows,

                                  POST OFFICE RESIDENCE ADDRESSES

GARY A. BELLER                    114 E. 72nd St.,
                                  New York, New York  10021

JOHN C. BOEDER                    9 Ridge Court,
                                  Saratoga Springs, New York  12866

ROGER C. COREA                    42 Harwood Lane,
                                  East Rochester, New York  14445

CHARLES A. CUCCINELLO             25 Dogwood Drive,
                                  Scarsdale, New York  10583

FRANCIS M. ELLIS                  90 Greene St.,
                                  New York, New York  10012

MILTON R. FENSTER                 1000 Park Avenue,
                                  New York, New York  10028

DAVID R. HUBERS                   72 E. Golden Lake Rd.,
                                  Circle Pines, Minnesota  55014

RICHARD W. KLING                  3790 Country Rd. #44,
                                  Minnetrista, Minnesota  55364

EDWARD LANDES                     5780 Schafer Rd.,
                                  Edina, Minnesota  55436

<PAGE>
PAGE 5
JAMES A. MITCHELL                 2685 North Shore Drive,
                                  Wayzata, Minnesota  55391

MICHAEL P. MONACO                 1735 York Avenue,
                                  New York, New York  10128

STEPHEN P. NORMAN                 6 Highland Park Place,
                                  Rye, New York  10580

GORDON H. RITZ                    560 Indian Mound, Apt. 4A,
                                  Wayzata, Minnesota  55391

MICHAEL R. WOODWARD               2707 Lockport Rd.,
                                  Oakfield, New York  14125

ARTICLE IX

     The duration of the corporate existence of this Corporation
shall be perpetual.

ARTICLE IX

     The holders of stock of the Corporation shall not have any
pre-emptive, preferential or other right to subscribe for or
purchase or acquire any shares of any class of stock or any other
securities of the Corporation, whether now or hereafter authorized,
and whether or not convertible into, or evidencing or carrying the
right to purchase, shares of stock of any class or any other
securities now or hereafter authorized and whether the same shall
be issued for cash, services or property, or by way of dividend, or
otherwise, other than such right, if any, as the Board of Directors
in its discretion from time to time may determine; but all such
shares of stock or other securities may be issued and disposed of
by the Board of Directors, to the extent permitted by law, in such
manner to such person or persons, on such terms, for such
consideration and for such corporate purposes as the Board of
Directors may deem advisable.

ARTICLE XI

     The amount of the authorized capital of this Corporation shall
be TWO MILLION ($2,000,000) DOLLARS, to consist of TWO HUNDRED
THOUSAND (200,000) shares of stock of the par value of TEN ($10.00)
DOLLARS per share.

ARTICLE XII
     The Corporation may establish, maintain and operate offices
and agencies and conduct business outside of the State of New York
and in other states, countries, territories, dependencies,
protectorates and in the District of Columbia, in such form and
manner as the Board of Directors may determine.

ARTICLE XIII
     The Board of Directors shall adopt By-Laws for its own
regulation and that of the conduct of the business of the
Corporation, which By-Laws shall nor be inconsistent with this 
<PAGE>
PAGE 6
Charter or with the laws of the State of New York, and which By-
Laws may be modified, rescinded or amended from time to time by
majority vote of the Board of Directors at any special meeting
called for that purpose, or at any regular meeting.


<PAGE>
PAGE 1
AMENDED BY-LAWS AS OF MAY 1992
OF
IDS LIFE INSURANCE COMPANY OF NEW YORK

ARTICLE I

LOCATION

     Section 1.  The principal office of the Corporation shall be
in the County of Albany and State of New York.  The Corporation
may, in addition to the principal office, establish and maintain
such other office or offices, whether in the State of New York or
otherwise, as the Board of Directors may from time to time
designate or the business of the Corporation may require.

ARTICLE II

CORPORATE SEAL

     Section 1.  The Corporation shall have a seal.  The corporate
seal shall have inscribed thereon the name of the Corporation.  The
corporate seal shall be in seal form and have inscribed thereon
such additional words and symbols as the Board of Directors may
from time to time prescribe.  The seal may be used by causing it or
a facsimile thereof to be impressed or affixed or otherwise
reproduced.

ARTICLE III

MEETINGS OF SHAREHOLDERS

     Section 1.  Time and Place.  All meetings of the shareholders
for the election of directors and all meetings of shareholders for
that or any other purpose may be held at such place within or
without the State of New York, and at such time as may be
designated in the notice of the meeting.
     Section 2.  Annual Meetings.  The annual meeting of
shareholders shall be held on the Thursday following the first
Tuesday on or after the nineteenth day of April in each year, if
not a legal holiday, and if a legal holiday, then on the next
succeeding business day, at 10:30 o'clock a.m. or at such other day
or hour as may from time to time be designated by the Board of
Directors.
     Section 3.  Special Meetings.  Except as otherwise provided by
statute, special meetings of shareholders may be called for any
purpose or purposes at any time by the Chairman of the Board of
Directors, the President, the Board of Directors, or by the
President or Secretary upon the written request of one or more
shareholders holding a majority in interest of the stock of the
Corporation issued and outstanding and entitled to vote at such
meeting.  Any such request shall state the purpose or purposes of
the proposed meeting.
     Section 4.  Notice of Meetings.  Notice of the time and place
of holding each annual and special meeting of the shareholders
shall be in writing and signed by the President or a Vice President
or the Secretary or an Assistant Secretary and a copy thereof shall
<PAGE>
PAGE 2
be served, either personally or by mail, upon each shareholder
entitled to vote at such meeting, not less than ten or more than
fifty days before the meeting, and if mailed, it shall be directed
to such shareholder at his address as it appears on the books of
the Corporation a written request that notices intended for him be
mailed to some other address, in which case it shall be mailed to
the address designated in such request.
     The notice of every special meeting, besides stating the time
and place of such meeting, shall state the purpose or purposes
thereof, and no business other than that specified in such notice
or germane thereto shall be transacted at the meeting.
     Section 5.  Waiver of Notice.  Notice of meeting need not be
given (1) to any shareholder who submits a signed waiver of notice,
in person or by proxy, whether before or after the meeting, or (2)
to any shareholder who is in attendance at any meeting, in person
or by proxy, without protesting prior to the conclusion of the
meeting the lack of notice of such meeting.
     Section 6.  Quorum.  At every meeting of the shareholders of
the Corporation, except as otherwise provided by law, the holders
of a majority of the issued and outstanding shares of capital stock
of the Corporation, present in person or by proxy and entitled to
vote thereat, shall constitute a quorum for the transaction of
business.  In the absence of a quorum a majority in interest of the
shareholders so present or represented and entitled to vote thereat
may adjourn the meeting from time to time and place to place until
a quorum is obtained, and the meeting may be held as adjourned
without further notice.  At any such adjourned meeting at which a
quorum is present any business maybe transacted which might have
been transacted at the meeting as originally called.  The
shareholders present at a duly called or held meeting at which a
quorum is present may continue to transact business until a final
adjournment, notwithstanding the withdrawal of enough shareholders
to leave less than a quorum.
     Section 7.  Voting.  At all meetings of shareholders every
shareholder entitled to vote thereat shall be entitled to one vote,
in person or by proxy, for each share of stock outstanding in his
name on the books of the Corporation on the date for the
determination of shareholders entitled to vote at such meetings. 
Every proxy must be executed in writing by the shareholder or by
his duly authorized attorney and must be delivered to the secretary
of the meeting.  No proxy shall be valid after the expiration of
eleven months from the date of its execution unless the shareholder
executing it shall have specified therein a longer duration.  At
all meetings of the shareholders, a quorum being present, all
matters except as otherwise provided by law, or the Charter of the
Corporation, or these By-Laws shall be decided by a majority in
interest of the shareholders of the Corporation present in person
or by proxy and entitled to vote.  All elections of directors may,
but need not be, held by ballot.
     Section 8.  Organization.  Meetings of the shareholders shall
be presided over by the Chairman of the Board of Directors or, if
he is not present, by the President or, if none of the foregoing is
present, by a chairman to be chosen by a majority of the
shareholders entitled to vote who are present in person or by proxy
at the meeting.  The Secretary of the Corporation, or in his
absence an Assistant Secretary, shall act as secretary of every 
<PAGE>
PAGE 3
meeting, but if neither the Secretary nor an Assistant Secretary is
present, the meeting shall choose any person present to act as
secretary of the meeting.     
     Section 9.  Consents.  Whenever by any provision of law or of
the Charter of this Corporation, the vote of shareholders at a
meeting thereof is required or permitted to be taken in connection
with any corporate action, the meeting and vote of shareholders may
be dispensed with, if all the shareholders who would have been
entitled to vote upon the action if such meeting were held, shall
consent in writing to such action being taken.  However, this
section shall not be construed to alter or modify any provision of
law or of the Charter under which the written consent of the
holders of less than all outstanding shares is sufficient for
corporate action.

ARTICLE IV

BOARD OF DIRECTORS

     Section 1.  Election and Qualification of Directors. 
Directors shall be elected at the annual meeting of shareholders by
a plurality of the votes cast and shall hold office for one year
until their respective successors shall have been elected and shall
have qualified.  All directors shall be of full age and at least a
majority shall be citizens and residents of the State of New York
or of adjoining states and not less than three (3) shall be
residents of the State of New York.  Directors need not be
shareholders.
     Section 2.  Number of Directors.  The number of directors
shall not be less than thirteen (13) nor more than twenty-three
(23) subject to change by action of the shareholders or by
resolution of the Board of Directors, the number of directors of
the Corporation shall be fourteen (14).  Any change in the number
of directors made by resolution of the Board of Directors shall
require the affirmative cote of a majority of all directors then in
office but no decrease in the number of directors so made shall
shorten the term of any incumbent directors.
     Section 3.  Vacancies.  A vacancy or vacancies in the Board
resulting from death, resignation or removal of any director or
from the increase in the number of directors, or for any other
cause, may be filled for the remainder of the term by majority vote
of the remaining directors at any regular meeting of the Board or
at any special meeting called for that purpose.  A director so
elected shall not take office or exercise the duties thereof until
ten (10) days after written notice of his election shall have been
filed in the office of the Superintendent of Insurance of the State
of New York.
     Section 4.  Duties and Powers.  The Board of Directors shall
have control and management of the affairs and property of the
Corporation and may adopt such rules and regulations for the
conduct of their meetings and the management of the Corporation as
they deem proper and not inconsistent with law or with the Charter
of the Corporation or with these By-Laws.
     Section 5.  Meetings.  Meetings of the Board of Directors
shall be held at such place within or without the State of New York
as may from time to time be fixed by resolution of the Board of 
<PAGE>
PAGE 4
Directors, or as may be specified in the notice of the meeting. 
Regular meetings of the Board of Directors shall be held at such
times as may from time to time be fixed by resolution of the Board
of Directors, and special meetings may be held at any time upon the
call of the Chairman of the Board of Directors, the President or
any Vice President or the Secretary or an Assistant Secretary or
any two directors by oral, telegraphic or written notice duly
served on or sent or mailed to each director not less than two days
before such meeting.  A meeting of the Board of Directors may be
held without notice immediately after the annual meeting of
shareholders.  Notice need not be given of regular meetings of the
Board of Directors.  Meetings may be held at any time without
notice if all the directors are present, or if at any time before
or after the meeting those not present waive notice of the meeting
in writing.
     Section 6.  Quorum.  A majority of the Board of Directors then
in office at a meeting duly assembled shall be necessary to
constitute a quorum for the transaction of business.  Except as
otherwise provided by law or by the Charter of the Corporation, the
act of a majority of directors present at such meeting shall be the
act of the Board.
     Section 7.  Resignations.  Any director of the Corporation may
resign at any time by giving written notice to the Board or to the
President or to the Secretary of the Corporation.  Such resignation
shall take effect at the time specified therein; and unless
otherwise specified therein the acceptance of such resignation
shall not be necessary to make it effective.
     Section 8.  Removal.  Any one or more of the directors may be
removed either with or without cause at any time by a vote of a
majority of the shares issued and outstanding and entitled to vote. 
Not less than one-third of the directors may call a special meeting
for the purpose of removing for cause any other director and at
such special meeting so called, such director may be removed by the
affirmative vote of a majority of the remaining directors present
at such meeting.  Immediately following each vote by which a
director is removed the Board of Directors shall declare the office
of the removed director to be vacant.
     Section 9.  Compensation of Directors.  Directors may, by
resolution of the Board of Directors, be allowed a fixed sum for
serving as directors and expenses for attendance at regular or
special meetings of the Board of Directors; provided that nothing
herein contained shall be construed to preclude any director from
servicing the Corporation in any other capacity and receiving
compensation therefor.  Members of special or standing committees,
and others who attend pursuant to direction, may, by vote of the
Board of Directors, be allowed a fixed sum and expenses for
attending committee meetings.

ARTICLE V

COMMITTEES

     Section 1.  Executive Committee.  The Board of Directors may,
by resolution adopted by a majority of the entire Board, designate
an Executive Committee from among its members consisting of five
(5) or more directors as it may, in its discretion, think proper
and shall so designate by resolution.
<PAGE>
PAGE 5
     The Executive Committee shall have and may exercise, when the
Board is not in session, so far as may be permitted by law, all of
the rights and powers of the Board of Directors in the management
of the business and affairs of the Corporation, except to the
extent such powers of the Board are by resolution of the Board or
by these by-laws are reserved to the Board or to other committees
of the Board, and shall have power to authorize the seal of the
Corporation to be affixed to all papers which may require it; but
the Executive Committee shall not have power to fill vacancies in
any committee of the Board, or to make or amend the By-Laws of the
Corporation.
     The Board shall have the power at any time to fill vacancies
in, to change the membership of, to change the number of members
of, to designate one or more alternate members of, or to dissolve,
the Executive Committee.  The Executive Committee may make rules
for the conduct of its business and may appoint such committees and
assistants as it shall from time to time deem necessary.
     The Committee shall keep a record of its proceedings and shall
adopt its own rules of procedure except that a quorum shall consist
of at least three (3) members, not more than two (2) of whom may be
officers or salaries employees of the Corporation.  The Committee
shall submit copies of its minutes to the Board of Directors.
     Section 2.  Investment Committee.  The investments of the
Corporation shall be managed and controlled by an Investment
Committee.  The Investment Committee shall consist of at least five
(5) members who shall be appointed by the Board of Directors from
its own membership at the annual meeting of the Board of Directors
to serve until the next succeeding annual meeting and until their
successors on the Committee have been appointed.  The Board shall
have the power at any time to fill vacancies in, to change the
membership of, to change the number of members of, to designate one
or more alternative members of, or to dissolve, the Investment
Committee.
     The Investment Committee shall have and may exercise, when the
Board is not in session, all the rights and powers of the Board of
Directors to make, supervise, and control the investments of the
Corporation, inclusive of all real and personal property acquired
by the virtue of or incidental to any investment, to sell, assign,
exchange, lease or otherwise dispose of such investments and
property, and to do and perform all things deemed necessary and
proper in relation to such investments and property.
     The Committee shall keep a record of its proceedings and shall
adopt its own rules of procedure except that a quorum shall consist
of at least three (3) members not more than two (2) of whom may be
officers or salaries employees of the Corporation.  The Committee
shall submit copies of its minutes to the Board of Directors.
     Section 3.  Other Committees.  The Board of Directors may from
time to time by resolution create such other committee or
committees of Directors, officers, employees or other persons
designated by the Board, to advise the Board, the Executive
Committee and the officers and employees of the Corporation in all
such matters as the Board shall deem advisable, and with such
functions and duties as the Board shall by resolution prescribe.  A
majority of all members of any such committee may determine its 
<PAGE>
PAGE 6
action and fix the time and place of its meetings, unless the Board
of Directors shall otherwise provide.  The Board of Directors shall
have power to change the members of any such committee at any time,
and to discharge any such committee, either with or without cause
at any time.

ARTICLE VI

OFFICERS

     Section 1.  Officers.  The Board of Directors shall,
immediately after the organization of the Corporation, and
thereafter at their first meeting following the annual election of
directors, shall elect from their number a Chairman of the Board,
and shall also elect a President, Secretary and a Treasurer, who
need not be members of the Board of Directors.  The Board may, at
any time, also elect one or more Vice Presidents and such Assistant
Treasurers or Assistant Secretaries, or other officers, as it may
deem proper.  More than one office may be held by the same person,
except that the offices of President and Secretary may not be held
by the same person.
     Section 2.  Term.  Each officer of the Corporation elected by
the Board of Directors shall hold office until his successor is
chosen and qualified, or until he shall have died or resigned or
shall have been removed as hereinafter provided.  A vacancy in any
office arising from any cause may be filled by the Board of
Directors.
     Section 3.  Duties of the Chairman of the Board.  The Chairman
of the Board shall preside at all meetings of the shareholders and
of the Board of Directors.  He shall have such other powers and
perform such other duties as may be assigned to him by the Board of
Directors.
     Section 4.  Duties of the President.  The President shall be
the Chief Executive Officer of the Corporation.  He shall have
general and active supervision and direction over the business
offices of the Corporation, subject to the control of the Board of
Directors whose policies he shall execute.  He shall see that all
orders and resolutions of the Board of Directors are carried into
effect and shall, in the absence of the Chairman of the Board,
preside at all meetings of shareholders and of the Board of
Directors.  Except when inconsistent with the Corporation's
Charter, these By-Laws, or with the orders and resolutions of the
Board of Directors, he shall have the power to employ, fix the
duties, and discharge such employees as he may deem necessary and
proper.  The President shall make such reports to the Board of
Directors as it may require.
     Section 5.  Duties of Vice President.  Each Vice President
shall undertake such of the duties of the President, or such other
duties, as may be delegated to him from time to time by the
President or by the Board of Directors.
     Section 6.  Duties of Secretary.  The Secretary shall attend
all meetings of the shareholders, of the Board of Directors, and of
the Executive Committee of the Board, and record their proceedings
in a book kept for that purpose.  He shall perform other duties
incident to his office and such other duties as may be delegated to
him by the Board of Directors or the President.  He shall see that 
<PAGE>
PAGE 7
proper notice is given to all meetings of the shareholders of the
Corporation and of the Board of Directors, and he shall have charge
of the corporate seal, the minutes books, and such other Corporate
records as are not otherwise provided for.  He shall affix the seal
to any instrument requiring the same.  Any Assistant Secretary may
perform the duties of the Secretary in his absence and such of the
duties of the Secretary as may be delegated to him by that officer
or by the Board of Directors or the President.
     Section 7.  Duties of Treasurer.  The Treasurer shall be
charged with supervision of the keeping of the funds and books of
account of the Corporation and with their safekeeping shall carry
out such duties as are incident to his office and shall further
perform such other duties as may be delegated to him by the Board
of Directors or by the President.  Any Assistant Treasurer may
perform the duties of the Treasurer in his absence, and such of the
duties of the Treasurer as may be delegated to him by that officer
or by the Board of Directors or the President.
     Section 8.  Removal.  Any officer may be removed either with
or without cause at any time by a vote of a majority of the
Directors.

ARTICLE VII

SHARE CERTIFICATES

     Section 1.  Form of Certificates.  The shares of the
Corporation shall be represented by certificates, in such form as
the Board of Directors may from time to time prescribe, signed by
the Chairman of the Board of Directors, the President or a Vice
President and the Secretary or an Assistant Secretary or the
Treasurer or an Assistant Treasurer, and sealed with the seal of
the Corporation.  Such seal may be a facsimile, engraved or
printed.  Where any such certificate is signed by a transfer agent
or transfer clerk and by a registrar, the signatures of any such
Chairman of the Board of Directors, President, Vice President,
Secretary, Assistant Secretary, Treasurer, or Assistant Treasurer
upon such certificates may be facsimiles, engraved or printed.  In
case any such officer who has signed or whose facsimile signature
has been placed upon such certificate shall have ceased to be such
before such certificate is issued, it may be issued by the
Corporation with the same effect as if such officer had not ceased
to be such at the date of its issue.
     Every certificate representing shares issued by the
Corporation shall plainly state upon the face thereof the number,
kind and class of shares which it represents.
     Section 2.  Transfers.  Transfers of shares shall be made only
upon the books of the Corporation by the registered holders in
person or by power of attorney duly executed and acknowledged and
filed with the Secretary of the Corporation, or with a duly
appointed Transfer Agent acting for and on behalf of the Secretary,
and upon the surrender of the certificate or certificates for such
shares.
     Section 3.  Lost Certificates.  If any certificate of shares
shall be lost, the holder thereof shall forthwith notify the
Corporation of the facts and the Board of Directors or the
Executive Committee may then authorize a new certificate to be 
<PAGE>
PAGE 8
issued to him.  The Board of Directors or the Executive Committee
may in its discretion require, as a condition precedent, deposit of
a bond in such amount and in such form and with surety or sureties
as the Board or the said Committee may direct.
     Section 4.  Closing Share Books.  The Board of Directors or
the Executive Committee may by resolution prescribe a period not
less than ten (10) nor more than fifty (50) days prior to any
meeting of shareholders during which no transfer of shares on the
books of the Corporation may be made; or in lieu of prohibiting the
transfer of shares may fix a day and hour not less than ten (10)
nor more than fifty (50) days prior to the folding of any meeting
of shareholders as the time as of which shareholders entitled to
notice of and to vote at such meeting shall be determined or for
the taking of a dividend list.  The share books may also be closed
for the payment of dividends for such like period, if any, as may
be prescribed by resolution of the Board of Directors or the
Executive Committee.
     Section 5.  Transfer Agent and Registrar.   The Board of
Directors may appoint one or more transfer clerks or one or more
transfer agents and one or more registrars, and may require all
certificates for shares to bear the signature or signatures of any
of them.

ARTICLE VIII

INDEMNIFICATION OF CORPORATE PERSONNEL

     To the extent permitted and in the manner prescribed by law,
the Corporation shall indemnify any person made, or threatened to
be made, a party to any action, suit or proceeding, civil or
criminal, by reason of the fact that he, his testator or intestate,
is or was Director or Officer of the Corporation or of any other
corporation of any type or kind, domestic or foreign, which he
served in any capacity at the request of the Corporation, against
judgements, fines, amounts paid in settlement and reasonable
expenses (which the Corporation may advance), including attorneys'
fees, actually and necessarily incurred as a result of such action,
suit or proceeding, or any appeal therein.

The foregoing right of indemnification shall not be exclusive of
any other right to which any such person may be entitled.  Neither
the adoption of this provision nor any modification or repeal
hereof, or of any provision of any applicable law shall, unless
otherwise required by law, enlarge or diminish any right of
indemnification of a Director or Officer as it existed at the time
of accrual of the alleged cause of action asserted in the
threatened or pending action, suit or proceeding in which the
expenses were incurred or other amount was paid.

INDEMNIFICATION OF OTHER PERSONNEL

The Board, in its discretion, may authorize the Corporation to
indemnify any person, other than a Director or Officer, for
expenses incurred or other amounts paid in any civil or criminal
action, suit or proceeding, to which such person was, or was
threatened to be, made a party by reason of the fact that he, is 
<PAGE>
PAGE 9
testator or intestate, is or was an employee or agent of the
Corporation or of any other corporation of any type or kind,
domestic or foreign, which he served in any capacity at the request
of the Corporation, against judgements, fines, amounts paid in
settlement and reasonable expenses (which the Corporation may
advance), as a result of such action, suit or proceeding, or any
appeal therein.

ARTICLE IX

CONFLICT OF INTERESTS

     No director or officer, of the Corporation shall receive, in
addition to his fixed salary of compensation, any money or valuable
things, either directly or indirectly, or through any substantial
interest in any other corporation or business unit, for
negotiating, procuring, recommending or aiding in any purchase or
sale of property, or loan, made by the Corporation or any affiliate
or subsidiary thereof; nor shall he be pecuniarily interested,
either as principal, co-principal, agent or beneficiary, either
directly or indirectly, or through any substantial interest in any
other corporation or business unit, in any such purchase, sale or
loan.

ARTICLE X

AMENDMENTS

     Section 1.  Power to Amend.  These By-Laws may be altered,
repealed, or amended in whole or in part by the Board of Directors
at any regular meeting of the Board of Directors, or at a special
meeting called for that purpose, provided that notice of the
proposed change is incorporated in the notice of such special
meeting.
     Section 2.  Notice to Shareholders.  If any By-Law regulating
an impending election of directors is adopted, amended or repealed
by the Board of Directors, there shall be set forth in the notice
of the next meeting of shareholders for the election of directors
the By-Law so adopted, amended or repealed, together with a concise
statement of the changes made.     


<PAGE>
PAGE 1






                  Consent of Independent Auditors


We consent to the reference to our firm under the caption
"Independent Auditors" and to the use of our reports dated February
3, 1994 on the financial statements and financial statement
schedules of IDS Life Insurance Company of New York and our report
dated March 18, 1994 on the financial statements of IDS Life of New
York Accounts 4, 10, 11, 5, 6 and 9 for Variable Retirement and
Combination Retirement Annuities to be offered by IDS Life
Insurance Company of New York, in Post-Effective Amendment No. 21
to the Registration Statement (Form N-4 No. 2-78194) being filed
under the Securities Act of 1933 and the Investment Company Act of
1940.



Ernst & Young
Minneapolis, Minnesota
April 25, 1994

           INDEPENDENT AUDITORS
<PAGE>
PAGE 1






                  Report of Independent Auditors

The Board of Directors
IDS Life Insurance Company of New York

We have audited the financial statements of IDS Life Insurance
Company of New York as of December 31, 1993 and 1992, and for each
of the three years in the period ended December 31, 1993, and have
issued our report thereon dated February 3, 1994 (included
elsewhere in this Registration Statement).

Our audits also included the financial statement schedules I, V,
VI, VIII and IX included elsewhere in this Registration Statement. 
These schedules are the responsibility of the Company's management. 
Our responsibility is to express an opinion based on our audits.

In our opinion, the financial statement schedules referred to
above, when considered in relation to the basic financial
statements taken as a whole, present fairly, in all material
respects, the information set forth therein.



Ernst & Young
Minneapolis, Minnesota
February 3, 1994
<PAGE>
PAGE 2
<TABLE>
<CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE I - SUMMARY OF INVESTMENTS
OTHER THAN INVESTMENTS IN RELATED PARTIES ($ thousands)
AS OF DECEMBER 31, 1993

Column A                                     Column B        Column C        Column D
                                                                           Amount at which
Type of Investment                             Cost            Value       shown in the
                                                                           balance sheet
<S>                                       <C>             <C>             <C>
Fixed maturities:
  Bonds:
    United States Government and
     government agencies and
     authorities (a)                      $     199,783   $     204,423   $     199,783
    States, municipalities and
      political subdivisions                        105             120             105
    All other corporate bonds                   971,135       1,036,050         971,135

          Total fixed maturities              1,171,023   $   1,240,593       1,171,023

Mortgage loans on real estate                   123,337     XXXXXXXXXX          123,337
Policy loans                                     12,952     XXXXXXXXXX           12,952
Other investments                                 2,239                           2,239

          Total investments               $   1,309,551     XXXXXXXXXX    $   1,309,551



(a) - Includes mortgage-backed securities with a cost and market value of $199,783 and $204,423, 
</TABLE>
<PAGE>
PAGE 3
<TABLE>
<CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE V - SUPPLEMENTARY INSURANCE INFORMATION ($ thousands)
FOR THE YEAR ENDED DECEMBER 31, 1991

Column A          Column B      Column C      Column D      Column E      Column F

Segment           Deferred       Future       Unearned    Other policy    Premium
                   policy        policy       premiums     claims and     revenue
                 acquisition    benefits,                   benefits
                    cost         losses,                    payable
                               claims and
                                  loss
                                expenses
<S>              <C>           <C>           <C>          <C>             <C> 
Annuities        $   36,975    $  826,045    $    -       $    437        $   -  

Life, DI and
Long-term Care 
Insurance            29,320       146,471         -          1,036         5,289

Total            $   66,295    $  972,516    $    -       $  1,473        $5,289
</TABLE>
<TABLE>
<CAPTION>
Column A          Column G      Column H      Column I      Column J      Column K

Segment             Net         Benefits,   Amortization     Other        Premiums
                 investment      claims,    of deferred    operating      written
                   income      losses and      policy      expenses 
                               settlement   acquisition            
                                expenses        costs
<S>              <C>           <C>           <C>          <C>                <C>
Annuities        $   77,725    $      109    $  3,934     $   2,602          N/A 

Life, DI and
Long-term Care 
Insurance            16,905         6,814       2,985         2,317          N/A

Total            $   94,630    $    6,923    $  6,919     $   4,919          N/A
</TABLE>
                    <PAGE>
PAGE 4
<TABLE>
<CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE V - SUPPLEMENTARY INSURANCE INFORMATION ($ thousands)
FOR THE YEAR ENDED DECEMBER 31, 1992

Column A          Column B      Column C      Column D      Column E      Column F

Segment           Deferred       Future       Unearned    Other policy    Premium
                   policy        policy       premiums     claims and     revenue
                 acquisition    benefits,                   benefits
                    cost         losses,                    payable
                               claims and
                                  loss
                                expenses
<S>              <C>           <C>           <C>          <C>             <C> 
Annuities        $   45,708    $  966,645    $    -       $  1,130        $   -  

Life, DI and
Long-term Care 
Insurance            31,561       155,270         -            935         6,282

Total            $   77,269    $1,121,915    $    -       $  2,065        $6,282
</TABLE>
<TABLE>
<CAPTION>
Column A          Column G      Column H      Column I      Column J      Column K

Segment             Net         Benefits,   Amortization     Other        Premiums
                 investment      claims,    of deferred    operating      written
                   income      losses and      policy      expenses 
                               settlement   acquisition            
                                expenses        costs
<S>              <C>           <C>           <C>          <C>                <C>
Annuities        $   85,375    $       84    $  4,551     $   1,802          N/A 

Life, DI and
Long-term Care 
Insurance            16,696         6,899       3,586         4,601          N/A

Total            $  102,071    $    6,983    $  8,137     $   6,403          N/A
</TABLE>
<PAGE>
PAGE 5
<TABLE>
<CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE V - SUPPLEMENTARY INSURANCE INFORMATION ($ thousands)
FOR THE YEAR ENDED DECEMBER 31, 1993

Column A          Column B      Column C      Column D      Column E      Column F

Segment           Deferred       Future       Unearned    Other policy    Premium
                   policy        policy       premiums     claims and     revenue
                 acquisition    benefits,                   benefits
                    cost         losses,                    payable
                               claims and
                                  loss
                                expenses
<S>              <C>           <C>           <C>          <C>             <C> 
Annuities        $   53,300    $    1,059    $    -       $  1,707        $   -  

Life, DI and
Long-term Care 
Insurance            34,591           161         -            640         7,110

Total            $   87,891    $    1,220    $    -       $  2,347        $7,110
</TABLE>
<TABLE>
<CAPTION>
Column A          Column G      Column H      Column I      Column J      Column K

Segment             Net         Benefits,   Amortization     Other        Premiums
                 investment      claims,    of deferred    operating      written
                   income      losses and      policy      expenses 
                               settlement   acquisition            
                                expenses        costs
<S>              <C>           <C>           <C>          <C>                <C>
Annuities        $   93,943    $      103    $  7,707     $   4,459          N/A 

Life, DI and
Long-term Care 
Insurance            16,204         6,733       2,727         3,193          N/A

Total            $  110,147    $    6,836    $ 10,434     $   7,652          N/A
</TABLE>
<PAGE>
PAGE 6
<TABLE>
<CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE VI - REINSURANCE ($ thousands)
FOR THE YEARS ENDED DECEMBER 31, 1993, 1992 AND 1991

Column A                     Column B         Column C         Column D         Column E       Column F

                           Gross amount    Ceded to other    Assumed from         Net         % of amount
                                              companies     other companies      Amount     assumed to net
<S>                       <C>              <C>              <C>              <C>                 <C>    
For the year ended
  December 31, 1993

Life insurance
  in force                $     2,933,830  $       172,973  $       512,555  $     3,273,412     15.66%

Premiums:
  Life insurance
   & annuities            $         2,250  $           187  $           --   $         2,063      0.00%
  DI &
   long-term care
   insurance                        5,140               93              --             5,047      0.00%
Total premiums            $         7,390  $           280  $             0  $         7,110      0.00%


For the year ended
  December 31, 1992

Life insurance
  in force                $     2,192,426  $       179,976  $       592,792  $     2,605,242     22.75%

Premiums:
  Life insurance
   & annuities            $         2,251  $           208  $           --   $         2,043      0.00%
  DI &
   long-term care
   insurance                        4,386              147              --             4,239      0.00%
Total premiums            $         6,637  $           355  $             0  $         6,282      0.00%


For the year ended
  December 31, 1991

Life insurance
  in force                $     1,961,086  $       183,198  $       704,500  $     2,482,388     28.38%

Premiums:
  Life insurance
   & annuities            $         2,230  $           320  $           --   $         1,910      0.00%
  DI &
   long-term care
   insurance                        3,491              112              --             3,379      0.00%
Total premiums            $         5,721  $           432  $             0  $         5,289      0.00%
</TABLE>
<PAGE>
PAGE 7
<TABLE>
<CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE VIII - VALUATION AND QUALIFYING ACCOUNTS ($ thousands)
FOR THE YEARS ENDED DECEMBER 31, 1993, 1992 AND 1991

Column A          Column B       Column C                           Column D         Column E

                                 Additions
                               --------------
                  Balance at                       Charged to
Description       Beginning      Charged to      Other Accounts-   Deductions-     Balance at End
                  of Period   Costs & Expenses      Describe        Describe         of Period
<S>                 <C>              <C>                <C>             <C>           <C>
For the year ended
  December 31, 1993
- ------------------------------
Reserve for
 Mortgage Loans     $500             ($55)              $0              $0              $445
Reserve for
 Fixed Maturities   $1,159           $493               $0              $0            $1,652

For the year ended
  December 31, 1992
- ------------------------------
Reserve for
 Mortgage Loans     $200             $300               $0              $0              $500
Reserve for
 Fixed Maturities   $3,737          ($2,578)            $0              $0            $1,159


For the year ended
  December 31, 1991
- ------------------------------
Reserve for
 Mortgage Loans     $0               $200               $0              $0              $200
Reserve for
 Fixed Maturities   $1,033           $2,704             $0              $0            $3,737
</TABLE>
<PAGE>
PAGE 8
<TABLE>
<CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE IX - SHORT-TERM BORROWINGS ($ thousands)
FOR THE YEARS ENDED DECEMBER 31, 1993, 1992 AND 1991

Column A                  Column B        Column C        Column D        Column E       Column F
                                                          Maximum         Average        Weighted
                                          Weighted         amount          amount         average
Category of aggregate     Balance         average       outstanding     outstanding    interest rate
short-term borrowing      at end          interest       during the       during the     during the
                         of period          rate           period         period         period
<S>                        <C>              <C>           <C>              <C>             <C>
1993
Line of Credit             $1,519           N/A           $10,495          $  638          3.92%

1992
Line of Credit               $  0           N/A           $10,685          $  434          6.05%

1991
Line of Credit               $  0           N/A           $ 5,110          $  506          8.39%
</TABLE>

<PAGE>
PAGE 1
              IDS LIFE OF NEW YORK INSURANCE COMPANY
                         POWER OF ATTORNEY


City of Minneapolis

State of Minnesota

     Each of the undersigned, as officers and/or directors of the
below listed unit investment trusts that previously have filed
registration statements and amendments thereto pursuant to the
requirements of the Securities Act of 1933 and the Investment
Company Act of 1940 with the Securities and Exchange Commission:
<TABLE>
<CAPTION>
                                                        1933 Act        1940 Act
                                                        Reg. Number     Reg. Number
<S>                                                     <C>             <C>
IDS Life of New York 4, 5, 6, 9, 10 and 11 
  IDS Life of New York Flexible Annuity                 33-4174         811-3500
IDS Life of New York 4, 5, 6, 9, 10 and 11
  IDS Life of New York Variable Retirement
  and Combination Retirement Annuity                    2-78194         811-3500
IDS Life of New York Account 8
  Flexible Premium Variable Life Insurance Policy       33-15290        811-5213
IDS Life of New York Account SBS
  IDS Life Symphony Annuity                             33-45776        811-6560
IDS Life of New York Account 7
  Single Premium Variable Life Insurance Policy         33-10334        811-4913
</TABLE>

hereby constitutes and appoints William A. Stoltzmann, Mary Ellyn
Minenko and Colleen Curran or either one of them, as her or his
attorney-in-fact and agent, to sign for her or him in her or his
name, place and stead any and all filings, applications (including
applications for exemptive relief), periodic reports, registration
statements (with all exhibits and other documents required or
desirable in connection therewith) other documents, and amendments
thereto and to file such filings, applications, periodic reports,
registration statements other documents, and amendments thereto
with the Securities and Exchange Commission, and any necessary
states, and grants to any or all of them the full power and
authority to do and perform each and every act required or
necessary in connection therewith.

     Dated the 18th day of April, 1994.



                                        /s/ Michael P. Monaco    
                                            Michael P. Monaco


/s/ John C. Boeder                      /s/ Stephen P. Norman    
    John C. Boeder                          Stephen P. Norman


/s/ Roger C. Corea                      /s/ Louise M. Parent     
    Roger C. Corea                          Louise M. Parent
<PAGE>
PAGE 2
/s/ Charles A. Cuccinello               /s/ Carl Platou          
    Charles A. Cuccinello                   Carl Platou    


/s/ Milton R. Fenster                   /s/ Gordon H. Ritz       
    Milton R. Fenster                       Gordon H. Ritz


                                        /s/ F. Dale Simmons        
                                            F. Dale Simmons


/s/ Richard W. Kling                    /s/ Michael R. Woodward  
    Richard W. Kling                        Michael R. Woodward


/s/ Edward Landes           
    Edward Landes



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