IDS LIFE OF NEW YORK ACCOUNT 4
485BPOS, 1995-04-27
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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.  22  (File No. 2-78194)       X  

                              and/or

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940

     Amendment No.  15  (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 485
  X  on May 1, 1995 pursuant to paragraph (b) of Rule 485
     60 days after filing pursuant to paragraph (a)(i) of Rule 485
     on (date) pursuant to paragraph (a)(i) of Rule 485
     75 days after filing pursuant to paragraph (a)(ii) of Rule 485
     on (date) pursuant to paragraph (a)(ii) of Rule 485.

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 28, 1995.
<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

                                                                    Section in
                  Section                                           Statement of
  Item No.        in Prospectus                     Item No.        Additional Information
    <S>        <C>                                     <C>          <C>
    1          Cover page                              15           Cover page

    2          Key terms                               16           Table of contents

    3(a)       Expense summary                         17(a)        NA
     (b)       The Flexible Annuity in brief             (b)        NA
                                                         (c)        About IDS Life of New York*
    4(a)       Condensed financial information
     (b)       Performance information                 18(a)        NA
     (c)       Financial statements                      (b)        NA
                                                         (c)        Independent Auditors
    5(a)       Cover page; About IDS Life of New York    (d)        NA
     (b)       The variable accounts                     (e)        NA
     (c)       The funds                                 (f)        NA
     (d)       Cover page, The funds
     (e)       Voting rights                           19(a)        Distribution of the contracts*;
     (f)       NA                                                   About IDS Life of New York*
     (g)       NA                                        (b)        Charges*
                  
    6(a)       Charges                                 20(a)        Principal underwriter
     (b)       Charges                                   (b)        Principal underwriter
     (c)       Charges                                   (c)        Principal underwriter
     (d)       Distribution of the contracts             (d)        NA                   
     (e)       The funds                                              
     (f)       NA                                      21(a)        Performance information
                                                         (b)        Performance information
    7(a)       Buying your annuity;                      
               Benefits in case of death;              22           Calculating annuity payouts
               The annuity payout period                                                       
     (b)       The variable accounts;                  23(a)        Financial statements
               Making the most of your annuity           (b)        Financial statements
     (c)       The funds; Charges    
     (d)       Cover Page                        
     (c)       The funds; Charges    

    8(a)       The annuity payout period
     (b)       Buying your annuity
     (c)       The annuity payout period
     (d)       The annuity payout period
     (e)       The annuity payout period
     (f)       The annuity payout period

    9(a)       Benefits in case of death
     (b)       Benefits in case of death

   10(a)       Buying your annuity; Valuing your investment
     (b)       Valuing your investment
     (c)       Buying your annuity; Valuing your investment
     (d)       About IDS Life of New York

   11(a)       Surrendering your contract
     (b)       NA
     (c)       Surrendering your contract
     (d)       Buying your annuity
     (e)       The Flexible Annuity in brief

   12(a)       Taxes
     (b)       Key terms
     (c)       NA

   13          NA

   14          Table of contents of the Statement of Additional Information<PAGE>
PAGE 3
*Designates page number in the prospectus, which is hereby incorporated by reference
in this Statement of Additional Information.
/TABLE
<PAGE>
PAGE 4
IDS Life of New York Variable Retirement and Combination Retirement
Annuities
   
Prospectus
May 1, 1995
       
This prospectus describes two individual deferred annuity contracts
offered by IDS Life Insurance Company of New York (IDS Life of New
York), a subsidiary of IDS Life Insurance Company (IDS Life), which
is a subsidiary of American Express Financial Corporation.  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 FINANCIAL INSTITUTION AND THE
SECURITIES IT OFFERS ARE NOT DEPOSITS OR OBLIGATIONS OF, OR
GUARANTEED OR ENDORSED BY ANY FINANCIAL INSTITUTION NOR ARE THEY
INSURED BY THE FEDERAL DEPOSIT INSURANCE CORPORATION, THE FEDERAL
RESERVE BOARD OR ANY OTHER AGENCY.
    <PAGE>
PAGE 5
   
A Statement of Additional Information (SAI) dated May 1, 1995
(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 6
                         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................................................
     How 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..........................................
     How 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...................................................
Distribution of the contracts...................................
About IDS Life of New York......................................
Regular and special reports.....................................
Table of contents of the Statement of Additional Information....
    <PAGE>
PAGE 7
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 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 annuity
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 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 8
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
lifetime or other forms of payouts to you or to anyone you
designate.
       
   
Ten-day free look:  You may return your annuity to your financial
advisor 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 9
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 financial advisor 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.)
   
Benefits 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.)
    <PAGE>
PAGE 10
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.  (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 contract 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 surrender within the first 11 contract 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 the Variable and Combination Retirement
Annuities in all cases is further limited so that it will never
exceed 8.5% of aggregate purchase payments made to the contract.
    
Annual contract administrative charge -
Variable Retirement Annuity - $20
Combination Retirement Annuity - $30
<PAGE>
PAGE 11
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     .64%            .89%           .64%         .64%        .64%         .54%   

  Other expenses      .04             .16            .04          .04         .04          .02  

  Total*              .68%           1.05%           .68%         .68%        .68%         .56% 

*Annualized operating expenses of underlying mutual funds at Dec.
31, 1994.

Example for the Variable Retirement Annuity:*

          Aggressive   International    Capital                 Special
            Growth        Equity        Resource    Managed     Income     Moneyshare

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:


1 year    $ 90.09        $ 93.61        $ 90.09     $ 90.09     $ 90.09     $ 88.94

3 years    110.23         121.12         110.23      110.23      110.23      106.68

5 years    130.24         148.95         130.24      130.24      130.24      124.11 

10 years   206.51         246.08         206.51      206.51      206.51      193.36

You would pay the following expenses on the same investment
assuming no surrender or selection of an annuity payout plan at the
end of each time period:

1 year    $ 17.84        $ 21.63        $ 17.84     $ 17.84     $ 17.84     $ 16.61

3 years     55.24          66.74          55.24       55.24       55.24       51.50 

5 years     95.10         114.45          95.10       95.10       95.10       88.76 

10 years   206.51         246.08         206.51      206.51      206.51      193.36 
</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 $20 annual contract administrative charge is
approximated as a .060% charge based on our average contract size.
    <PAGE>
PAGE 12
Example for the Combination Retirement Annuity:**
    <TABLE><CAPTION>
         Aggressive   International    Capital                 Special
            Growth        Equity        Resource    Managed     Income     Moneyshare

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:
<S>      <C>             <C>            <C>         <C>         <C>         <C> 
1 year   $ 91.31         $ 94.83        $ 91.31     $ 91.31     $ 91.31     $ 90.16    

3 years   135.91          146.54         135.91      135.91      135.91      132.45  

5 years   183.31          201.07         183.31      183.31      183.31      177.49   

10 years  247.46          285.56         247.76      247.76      247.76      234.81  

You would pay the following expenses on the same investment
assuming no surrender or selection of an annuity payout plan at the
end of each time period:

1 year   $ 19.15         $ 22.94        $ 19.15     $ 19.15     $ 19.15     $ 17.92

3 years    59.23           70.70          59.23       59.23       59.23       55.49

5 years   101.83          121.08         101.83      101.83      101.83       95.52 

10 years  220.36          259.44         220.36      220.36      220.36      207.38 

</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 .188% charge based on our average contract size.
    <PAGE>
PAGE 13
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,                                   
                                  1994     1993     1992     1991     1990     1989     1988     1987     1986     1985 
<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 ............    $3.43    $3.35    $3.25    $2.24    $2.25    $1.78    $1.61    $1.44    $1.33    $1.06
Accumulation unit value at end
of year ......................    $3.43    $3.43    $3.35    $3.25    $2.24    $2.25    $1.78    $1.61    $1.44    $1.33
Number of accumulation units
outstanding at end of year
(000 omitted) ................   38,283   30,089   21,677   13,591   10,058    8,345    7,347    7,342    5,640    3,8971
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 102 (investing in shares of International Equity Fund)
Accumulation unit value at
beginning of period ..........    $1.29    $0.98    $1.00       -        -        -        -        -        -        - 

Accumulation unit value at end
of period ....................    $1.25    $1.29     $0.98      -        -        -        -        -        -        - 
Number of accumulation units
outstanding at end of period
(000 omitted) ................   51,480   21,650     3,421      -        -        -        -        -        -        - 
Ratio of operating expense to
average net assets ...........    1.00%    1.00%     1.00%      -        -        -        -        -        -        - 

Account 113 (investing in shares of Aggressive Growth Fund)
Accumulation unit value at
beginning of period ..........    $1.21    $1.08     $1.00      -        -        -        -        -        -        -
Accumulation unit value at end
of period ....................    $1.12    $1.21     $1.08      -        -        -        -        -        -        - 
Number of accumulation units
outstanding at end of period
(000 omitted) ................   45,347   19,430     5,961      -        -        -        -        -        -        - 
Ratio of operating expense to
average net assets ...........    1.00%    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.
<PAGE>
PAGE 14
                                                                   Years Ended Dec. 31,                                 
                                  1994     1993     1992     1991     1990     1989     1988     1987     1986     1985 
Account 5 (investing in shares of Special Income Fund)
Accumulation unit value at
beginning of year ............    $3.06    $2.67    $2.46    $2.12    $2.05    $1.90    $1.74    $1.74    $1.48    $1.22
Accumulation unit value at end
of year ......................    $2.91    $3.06    $2.67    $2.46    $2.12    $2.05    $1.90    $1.74    $1.74    $1.48
Number of accumulation units
outstanding at end of year
(000 omitted) ................   21,936   23,259   16,710   12,228   10,315    9,301    7,891    8,093    7,151   3,8304 
________________________________________________________________________________________________________________________
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 6 (investing in shares of Moneyshare Fund)
Accumulation unit value at
beginning of year ............    $1.86    $1.83    $1.80    $1.71    $1.61    $1.49    $1.40    $1.33    $1.26    $1.18
Accumulation unit value at end
of year ......................    $1.91    $1.86    $1.83    $1.80    $1.71    $1.61    $1.49    $1.40    $1.33    $1.26
Number of accumulation units
outstanding at end of year
(000 omitted) ................    3,794    4,113    5,378    7,253    6,487    5,493    2,836    2,125     1,055    8655
________________________________________________________________________________________________________________________
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 ................    4.39%    1.88%    1.77%    3.24%    6.20%    6.80%    7.30%    5.73%    4.16%    6.39%
________________________________________________________________________________________________________________________

Compound yield6 ..............    4.48%    1.90%    1.78%    3.29%    6.39%    7.03%    7.57%    5.90%    4.24%    6.59%
________________________________________________________________________________________________________________________

Account 97 (investing in shares of Managed Fund)
Accumulation unit value at
beginning of year ............    $2.21    $1.98    $1.86    $1.45    $1.42    $1.14    $1.06    $1.01    $1.00       - 
Accumulation unit value at end
of year ......................    $2.09    $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) ................   66,800   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%    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 risk fee.
7Account 9 commenced operations on April 30, 1986.
</TABLE>    
Financial statements
   
The SAI dated May 1, 1995, contains:
       
o   complete audited financial statements of the variable accounts
    including:
    - statements of net assets as of Dec. 31, 1994;
    - statements of operations for the year ended Dec. 31, 1994;
    and
    - statements of changes in net assets for the years ended Dec.
    31, 1994 and Dec. 31, 1993.
       
o   complete audited financial statements for IDS Life of New York
    including:
    - balance sheets as of Dec. 31, 1994 and Dec. 31, 1993; and
    - related statements of income and cash flows for each of       
    three years in the period ended Dec. 31, 1994.
    <PAGE>
PAGE 15
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 - Account 5 (investing in Special Income):  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).
   
Aggregate total return:  Represents the cumulative change in the
value of an investment over a specified period of time (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 advisor.
    <PAGE>
PAGE 16
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.  Each variable account's
net assets are held in relation to the contracts described in this
prospectus as well as other variable annuity contracts that we
issue that are not described in this prospectus.  All obligations
arising under the contracts are general obligations of IDS Life of
New York.
    
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
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.
<PAGE>
PAGE 17
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 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 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 advisor.
    <PAGE>
PAGE 18
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 advisor 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 
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.<PAGE>
PAGE 19
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 "Benefits 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 20
   
How 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 Ave. Extension
Albany, NY  12203

2    By scheduled payment plan
   
Your financial advisor 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.  The variable accounts pay this fee at the
time that dividends are distributed from the funds in which they
invest.  Annually the fee totals 1% of the variable accounts'
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 pay a death
benefit and 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.
    <PAGE>
PAGE 21
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.

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.
<PAGE>
PAGE 22
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.
   
Example of Withdrawal Charge:

You request a $1,000 partial withdrawal, and the withdrawal charge
is 5%:

    $1,000 partial withdrawal         =         $1,052.63
               .95

    Total amount withdrawn......................$1,052.63
                                                   x  0.05
     Total withdrawal charge.....................$   52.63
    
All of the above charges are guaranteed not to increase during the
term of the contract.
   
Other information on charges:  American Express Financial
Corporation 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 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<PAGE>
PAGE 23
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.

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
   account(s);
o  transfers into or out of the variable 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.
<PAGE>
PAGE 24
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 the average cost per unit.  For specific
features contact your financial advisor.
    
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 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 one account, including CRA's 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<PAGE>
PAGE 25
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 CRA's 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 CRA, or from the variable account(s) to the fixed account
for CRA at any time.  
       
For the Combination Retirement Annuity
o  If you have made a transfer from CRA's fixed account to the
   variable account(s), you may not make a transfer (including
   automated transfers) 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.
   
How 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<PAGE>
PAGE 26
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 advisor can help you set up automated transfers
among your accounts or partial surrenders from the accounts.
    
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 to
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.
<PAGE>
PAGE 27
Receiving payment when you request a surrender

By regular or express mail:

o  Payable to owner.

o  Mailed to address of record.
   
By wire:

o  Request that payment be wired to your bank;

o  Bank account must be in the same ownership as your contract;

o  Pre-authorization required.  For instructions, contact your
   financial advisor.
       
Payment normally will be sent 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;
    -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.")<PAGE>
PAGE 28
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.

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<PAGE>
PAGE 29
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.")

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.)
<PAGE>
PAGE 30
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.
   
o Plan E - Payouts for a specified period:  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.")
    
Restrictions 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.
<PAGE>
PAGE 31
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 dies 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. 
(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 of 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.
    
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<PAGE>
PAGE 32
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 payout.  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.
       
If the payout 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.<PAGE>
PAGE 33
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 deferred 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 after Aug. 13, 1982 will be taxed to you like a
surrender.
   
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 advisor if you have any questions about taxation of your
contract.
    
Tax qualifications:  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<PAGE>
PAGE 34
   
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 charges 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 is determined by
applying the percentage interest in each variable account to the
total number of votes allowed to the account.
       
After annuity payouts begin, the number of votes 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 annuity 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.
   
Distribution of the contracts

American Express Financial Advisors Inc., a registered
broker/dealer and an affiliate of IDS Life of New York, is the sole
distributor of the contract.  IDS Life of New York pays total
commissions of up to 7.0% of the total purchase payments received
on the contracts.  A portion of this total commission is paid to
district and division managers of the selling representative.
    
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 American Express Financial Corporation. 
American Express Financial Corporation is a wholly owned subsidiary
of the American Express Company.  American Express Company is a
financial services company principally engaged through subsidiaries<PAGE>
PAGE 35
(in addition to American Express Financial Corporation) 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.
       
   
American Express Financial Advisors Inc. offers mutual funds,
investment certificates and a broad range of financial management
services.  IDS Life of New York offers insurance and annuities.
       
American Express Financial Advisors Inc. serves individuals and
businesses through its nationwide network of more than 175 offices
and more than 8,000 financial advisors.
    
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, we
provide:
    
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 advisor.
    <PAGE>
PAGE 36
Table of contents of the Statement of Additional Information
   
Performance information.......................  3
Calculating annuity payouts...................  6
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 37
















                STATEMENT OF ADDITIONAL INFORMATION

                                for

     VARIABLE RETIREMENT AND COMBINATION RETIREMENT ANNUITIES

        IDS LIFE OF NEW YORK ACCOUNTS 4, 5, 6, 9, 10 AND 11
   
                            May 1, 1995
    

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 May 1, 1995, is not
a prospectus.  It should be read together with the Accounts'
prospectus, dated May 1, 1995, which may be obtained from your
financial advisor, 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 38
TABLE OF CONTENTS

Performance Information.......................................p. 3 
   
Calculating Annuity Payouts...................................p. 6
    
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 39
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, 1994, the account's annualized simple yield was 4.39%
and its compound yield was 4.48%.  
    
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 Account G
       
IDS Life Account G invests in IDS Life Special Income Fund, Inc. 
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:
    <PAGE>
PAGE 40
                         YIELD = 2[(a-b + 1)6 - 1]
                                     cd

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.
   
On Dec. 31, 1994, the account's annualized yield was 4.08%.
    
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.
<PAGE>
PAGE 41
Aggregate total return
   
Aggregate total return represents the cumulative change in the
value of an investment over a specified period of time (reflecting
change in an account's accumulation unit value) and is computed by
the following formula:
    
                               ERV - P
                                  P

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).
   
The following performance figures are calculated on the basis of
historical performance of the funds.
<TABLE><CAPTION>
   Average Annual Total Return for Period Ended:  Dec. 31, 1994

Average Annual Total Return with Surrender

                                                                                     Since
Account investing in:                 1 Year     3 Year     5 Year     10 Year     Inception
<S>                                   <C>        <C>        <C>         <C>           <C>
IDS LIFE
  Aggressive Growth Fund (1/92)*      -14.37                  ---         ---         1.73
  Capital Resource Fund (10/81)       - 6.98                7.65%       12.25%         ---   
  International Equity Fund (1/92)    -10.04                  ---         ---         5.63
  Managed Fund (4/86)                 -12.59                6.72          ---         8.28  
  Moneyshare Fund (10/81)             - 4.35                2.22         4.72          ---    
  Special Income Fund (10/81)         -12.04                6.00         8.83          --- 

Average Annual Total Return without Surrender
                                                                                     Since 
Account investing in:                 1 Year     3 Year     5 Year     10 Year     Inception

IDS LIFE
  Aggressive Growth Fund (1/92)*      -7.37%                 ---         ---         3.96% 
  Capital Resource Fund (10/81)         .02                 8.67%      12.25%         ---
  International Equity Fund (1/92)    -3.04                  ---         ---         7.71
  Managed Fund (4/86)                 -5.59                 7.78         ---         8.71
  Moneyshare Fund (10/81)              2.65                 3.47        4.72          ---  
  Special Income Fund (10/81)         -5.04                 7.09        8.83          --- 


*inception dates of the funds are shown in parentheses.
</TABLE>    
<PAGE>
PAGE 42
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.

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.
<PAGE>
PAGE 43
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.

RATING AGENCIES
   
The following chart reflects the ratings given to IDS Life of New
York by independent rating agencies.  These agencies evaluate the
financial soundness and claims-paying ability of insurance
companies based on a number of different factors.  This information
does not relate to the management or performance of the variable
accounts of the annuity.  This information relates only to the
fixed account and reflects IDS Life of New York's ability to make
annuity payouts and to pay death benefits and other distributions
from the annuity.
    <PAGE>
PAGE 44
   
Rating agency          Rating

A.M. Best                A+
                      (Superior)

Duff & Phelps           AAA

Moody's                 Aa2
    
PRINCIPAL UNDERWRITER
   
The principal underwriter for the accounts is American Express
Financial Advisors Inc. which offers the variable annuities on a
continuous basis.
       
Surrender charges received by IDS Life of New York for 1994, 1993
and 1992, aggregated $269,275, $151,536 and $136,471, respectively. 
Commissions paid by IDS Life of New York for 1994, 1993 and 1992,
aggregated $1,130,352, $1,244,668 and $631,691, respectively.  The
surrender charges were applied toward payment of commissions.
    
INDEPENDENT AUDITORS
   
The financial statements of IDS Life of New York Accounts 4, 10,
11, 5, 6 and 9 including the statements of net assets as of
December 31, 1994, and the related statements of operations for the
year then ended and the related statements of changes in net assets
for each of the two years in the period then ended, and the
financial statements of IDS Life Insurance Company of New York as
of December 31, 1994 and for each of the three years in the period
then ended, appearing in this SAI, have been audited by Ernst &
Young LLP, independent auditors, as stated in their reports
appearing herein.
    
PROSPECTUS
   
The prospectus dated May 1, 1995, is hereby incorporated in this
Statement of Additional Information by reference.
    <PAGE>
PAGE 45
<TABLE><CAPTION>
IDS Life of New York Accounts 4, 10, 11, 5, 6 and 9
 
Statements of Net Assets                                                                                            Dec. 31, 1994
                                                                                                                         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 - 5,773,766 shares
at net asset value of
$22.79 per share
(cost $133,165,260).... $131,552,101    $        --    $        --    $        --     $       --    $         --    $131,552,101
IDS Life International
Equity Fund - 5,378,938
shares at net asset value
of $11.98 per share
(cost $64,669,263).....           --     64,445,257             --             --             --              --      64,445,257
IDS Life Aggressive Growth
Fund - 4,433,502 shares at
net asset value of
$11.50 per share
(cost $49,664,409).....           --             --     51,001,900             --             --              --      51,001,900
IDS Life Special Income
Fund, Inc. - 5,975,493
shares at net asset value
of $10.63 per share
(cost $67,426,852).....           --             --             --     63,526,532             --              --      63,526,532
IDS Life Moneyshare
Fund, Inc. - 7,232,068
shares at net asset
value of $1.00 per share
(cost $7,231,480)......           --             --             --             --      7,231,487              --       7,231,487
IDS Life Managed Fund, Inc. 
Fund, Inc. - 10,763,220
shares at net asset value
of $12.97 per share
(cost $142,921,766)....           --             --             --             --             --     139,581,105     139,581,105
                         131,552,101     64,445,257     51,001,900     63,526,532      7,231,487     139,581,105     457,338,382
Dividends receivable...           --             33             --        428,663         32,445              --         461,141
Accounts receivable from
IDS Life of New York for
contract purchase
payments...............      105,797        104,029         68,345         30,205             --          75,462         383,838
Receivable from mutual funds
for share redemptions..           --             --             --         50,325         50,637              --         100,962
Total assets...........  131,657,898     64,549,319     51,070,245     64,035,725      7,314,569     139,656,567     458,284,323
Liabilities                                                                                                                     
Payable to IDS Life of New York for: 
Mortality and expense
risk fee...............      107,250         52,077         41,284         52,465          6,104         114,067         373,247
Contract terminations..           --             --             --         50,325         50,637              --         100,962
Payable to mutual funds
for investments
purchased..............      105,797        104,029         68,345         26,624         26,341          75,462         406,598
Total liabilities......      213,047        156,106        109,629        129,414         83,082         189,529         880,807
Net assets applicable to
contracts in accumulation
period.................  131,370,798     64,393,213     50,960,616     63,906,311      7,231,487     139,347,597     457,210,022
Net assets applicable to
contracts in payment
period.................       74,053             --             --             --             --         119,441         193,494
Total net assets....... $131,444,851    $64,393,213    $50,960,616    $63,906,311     $7,231,487    $139,467,038    $457,403,516
Accumulation units
outstanding............   38,283,499     51,479,988     45,346,878     21,935,625      3,793,729      66,799,845                
Net asset value per
accumulation unit...... $       3.43    $      1.25    $      1.12    $      2.91     $     1.91    $       2.09                

See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 46
<TABLE><CAPTION>
IDS Life of New York Accounts 4, 10, 11, 5, 6, and 9
 
Statements of Operations                                                                                  Year ended Dec. 31, 1994
                                                                                                                          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..........  $ 14,412,396    $ 1,748,669    $    69,863    $ 5,425,798     $  297,529    $  8,364,866    $ 30,319,121
Mortality and expense
risk fee (Note 3).....     1,172,157        497,717        366,652        682,000         79,769       1,283,210       4,081,505
Investment income
(loss) -- net.........    13,240,239      1,250,952       (296,789)     4,743,798        217,760       7,081,656      26,237,616


Realized and Unrealized Gain (Loss) on Investments -- net                                                                       
Realized gain (loss) on sales of investments in mutual funds: 
Proceeds from sales...       815,313         40,692        492,702     10,046,398      7,496,929       1,234,393      20,126,427
Cost of investments
sold..................       774,094         38,968        496,953     10,182,430      7,496,950       1,221,731      20,211,126
Net realized gain (loss) on
investments...........        41,219          1,724         (4,251)      (136,032)           (21)         12,662         (84,699)
Net change in unrealized
appreciation or depreciation
of investments........   (12,937,247)    (3,394,978)    (1,571,685)    (8,197,623)            (8)    (14,289,852)    (40,391,393)
Net gain (loss) on
investments...........   (12,896,028)    (3,393,254)    (1,575,936)    (8,333,655)           (29)    (14,277,190)    (40,476,092)
Net increase (decrease)
from operations.......  $    344,211    $(2,142,302)   $(1,872,725)   $(3,589,857)    $  217,731    $ (7,195,534)   $(14,238,476)

See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 47
<TABLE><CAPTION>
IDS Life of New York Accounts 4, 10, 11, 5, 6 and 9
 
Statements of Changes in Net Assets                                                                      Year ended Dec. 31, 1994
                                                                                                                         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.......   $ 13,240,239     $ 1,250,952   $  (296,789)   $ 4,743,798      $  217,760    $  7,081,656    $ 26,237,616
Net realized gain
(loss) on
investments........         41,219           1,724        (4,251)      (136,032)            (21)         12,662         (84,699)
Net change in
unrealized appreciation
or depreciation
of investments.....    (12,937,247)     (3,394,978)   (1,571,685)    (8,197,623)             (8)    (14,289,852)    (40,391,393)
Net increase (decrease)
from operations....        344,211      (2,142,302)   (1,872,725)    (3,589,857)         217,731     (7,195,534)    (14,238,476)
Contract Transactions                                                                                                           
Variable annuity contract
purchase payments..     18,920,075      17,412,099    13,231,024     12,729,002       5,008,226      24,260,004      91,560,430
Net transfers*.....     13,441,550      22,198,315    16,626,302    (13,515,187)     (4,575,639)     14,090,849      48,266,190
Loan repayments....        109,900          29,851        30,606         48,227           9,397         111,952         339,933 
Annuity payments...         (4,077)             --            --             --              --         (11,820)        (15,897)
Contract charges
(Note 3)...........       (149,334)        (57,760)      (46,731)       (71,099)         (6,935)       (154,009)       (485,868)
Contract terminations:
Surrender benefits.     (3,806,292)       (716,854)     (466,670)    (2,426,200)     (1,029,901)     (2,943,745)    (11,389,662)
Death benefits.....       (514,092)       (169,388)      (82,471)      (521,284)        (23,829)       (648,725)     (1,959,789)
Increase (decrease)
from contract
transactions.......     27,997,730      38,696,263    29,292,060     (3,756,541)       (618,681)     34,704,506     126,315,337
Net assets at beginning
of year............    103,102,910      27,839,252    23,541,281     71,252,709       7,632,437     111,958,066     345,326,655
Net assets at end
of year............   $131,444,851     $64,393,213   $50,960,616    $63,906,311      $7,231,487    $139,467,038    $457,403,516
Accumulation Unit Activity                                                                                                     
Units outstanding at
beginning of
year...............     30,089,286      21,650,329    19,430,140     23,259,461       4,113,215      50,761,194
Contract purchase
payments...........      5,550,328      13,493,341    11,706,736      4,301,276       2,690,867      11,309,731
Net transfers*.....      3,925,993      17,068,799    14,750,027     (4,563,976)     (2,421,933)      6,450,489
Transfers for
policy loans.......         31,960          23,044        27,321         16,366           4,923          52,360
Contract charges...        (44,486)        (45,188)      (42,134)       (24,217)         (3,807)        (73,063)
Contract terminations:
Surrender benefits.     (1,110,107)       (583,594)     (449,677)      (869,164)       (576,903)     (1,393,669)
Death benefits.....       (159,475)       (126,743)      (75,535)      (184,121)        (12,633)       (307,197)               
Units outstanding at
end of year.........    38,283,499      51,479,988    45,346,878     21,935,625       3,793,729      66,799,845                
*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.
<PAGE>
PAGE 48
IDS Life of New York Accounts 4, 10, 11, 5, 6 and 9

Statements of Changes in Net Assets                                                                       Year ended Dec. 31, 1993
                                                                                                                          Combined
                                                          Segregated Asset Account                                      Retirement
  Operations                    4               10             11            5                6              9             Annuity
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 49
IDS Life of New York Accounts 4, 10, 11, 5, 6 and 9

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 on 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 10 invests in
the shares of IDS Life International Equity Fund; IDS Life of New
York Account 11 invests in the shares of IDS Life Aggressive Growth
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. and IDS
Life of New York Account 9 invests in the shares of IDS Life
Managed Fund, Inc.

IDS Life, parent company of IDS Life of New York, serves as
manager, investment adviser and underwriter for the underlying six
mutual funds. American Express Financial Advisors Inc., formerly
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.<PAGE>
PAGE 50
___________________________________________________________________
2.  Summary of Significant Accounting Policies (continued)

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
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.  An annual charge of $30 is deducted from the
certificate value of each Employee Benefit Annuity Certificate.  A
quarterly charge of $6 is deducted from the certificate 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,

c) Employee Benefit Annuity Certificate surrenders during the first
   eleven years, and<PAGE>
PAGE 51
d) 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 $269,275 in 1994 and $151,536
in 1993.  Such charges are not an expense of the Accounts.  They
are deducted from contract surrender benefits paid by IDS Life of
New York.

___________________________________________________________________
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                                    1994           1993  
  <S>     <C>                                      <C>             <C> 
   4      IDS Life Capital Resource Fund........   $ 42,073,838    $ 32,417,890
  10      IDS Life International Equity Fund....     40,017,816      21,363,338
  11      IDS Life Aggressive Growth Fund.......     29,510,159      14,993,546
   5      IDS Life Special Income Fund, Inc.....     10,653,876      24,487,045
   6      IDS Life Moneyshare Fund, Inc.........      7,096,008       3,917,840
   9      IDS Life Managed Fund, Inc............     43,041,591      44,777,396
                                                   $172,393,288    $141,957,055
</TABLE>
___________________________________________________________________
5. Annuity Contracts in Payment Period

Net assets and annuity units relating to contracts in the payment
period as of Dec. 31, 1994 are as follows:

<TABLE><CAPTION>
                              4       10      11       5      6       9    
<S>                        <C>      <C>     <C>      <C>    <C>    <C>
Net assets applicable
to contracts in payment
period.................    $74,053  $    -  $    -   $   -  $   -  $119,441
Annuity units in
payment period.........        341       -       -       -      -     1,715
/TABLE
<PAGE>
PAGE 52
IDS Life of New York Accounts 4, 10, 11, 5, 6 and 9

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, 1994, 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. 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, 1994. 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, 1994, 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 LLP
Minneapolis, Minnesota
March 17, 1995
<PAGE>
PAGE 53
The financial statements shown below are those of the insurance
company and not those of the Funds or the Accounts.  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 SHEETS
December 31,

ASSETS                                                                              1994                         1993   
                                                                                              (thousands)
<S>                                                                            <C>                            <C>
Investments:
Fixed maturities:
Held to maturity, at amortized cost (Fair value: 1994, $653,080)               $  686,483                     $       -
 Available for sale, at fair value (Amortized cost: 1994, $474,599)               455,103                              -
Investment securities, at amortized cost (Fair value: 1993, 
$1,240,593)                                                                             -                       1,171,023
Mortgage loans on real estate
(Fair value:  1994, $157,085; 1993, $124,030)                                     164,916                         123,337
Policy loans                                                                       14,899                          12,952
Other investments                                                                   1,524                           2,239

Total investments                                                               1,322,925                       1,309,551

Cash and cash equivalents                                                           5,262                               -

Accrued investment income                                                          21,517                          21,342

Deferred policy acquisition costs                                                 100,078                          87,891

Other assets                                                                        1,584                           2,270

Assets held in segregated asset accounts,
primarily common stocks at market                                                 506,208                         380,796

 Total assets                                                                  $1,957,574                      $1,801,850
                                                                                =========                       =========   

<PAGE>
PAGE 54
IDS LIFE INSURANCE COMPANY OF NEW YORK
BALANCE SHEETS (continued)
December 31,

LIABILITIES AND STOCKHOLDER'S EQUITY                                                1994                         1993   
     (thousands)       


Liabilities:
Fixed annuities - future policy benefits                                      $1,087,367                     $1,059,005
Universal life-type insurance - future policy benefits                           127,871                        120,917
Traditional life, disability income and long-term care
insurance - future policy benefits                                                40,546                         40,045
Policy claims and other policyholders' funds                                       3,217                          2,347
Deferred income taxes                                                              2,044                         13,018
Amounts due to brokers                                                                 -                          4,952
Other liabilities                                                                 18,600                         20,311
Liabilities related to segregated asset accounts                                 506,208                        380,796

Total liabilities                                                              1,785,853                      1,641,391

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 gain (loss) on investments                                        (12,369)                            24
Retained earnings                                                                133,090                        109,435

Total stockholder's equity                                                       171,721                        160,459

Total liabilities and stockholder's equity                                    $1,957,574                     $1,801,850
                                                                               =========                      =========

Commitments and contingencies (Note 7)

                         See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 55
<TABLE><CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF INCOME
Years ended December 31,

                                                                            1994               1993                1992
                                                                                         (thousands)           
<S>                                                                     <C>               <C>                 <C>
Revenues:
Traditional life, disability income and long-term care
insurance premiums                                                      $  7,846          $  7,110            $  6,282
Policyholder and contractholder charges                                   11,607             9,634               8,359
Mortality and expense risk fees                                            4,562             2,904               1,696
Net investment income                                                    108,143           110,147             102,071
Net gain on investments                                                      957             1,334               2,478
Total revenues                                                           133,115           131,129             120,886

Benefits and expenses:
Death and other benefits - traditional life disability income
and long-term care insurance                                               6,016             5,715               5,705
Death and other benefits - universal life-type insurance
and investment contracts                                                   3,773             2,465               2,133
Increase (decrease) in liabilities for future policy benefits
for traditional life, disability income and long-term care
insurance                                                                    506            (1,343)               (855)
Interest credited on universal life-type insurance and
investment contracts                                                      65,018            68,987              68,487
Amortization of deferred policy acquisition costs                         12,994            10,434               8,137
Other insurance and operating expenses                                     8,359             7,652               6,403
Total benefits and expenses                                               96,666            93,910              90,010

Income before income taxes                                                36,449            37,219              30,876


Income taxes                                                              12,794            13,335              10,914


Net income                                                              $ 23,655          $ 23,884            $ 19,962
                                                                          ======            ======              ======


See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 56
<TABLE><CAPTION>
IDS LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF CASH FLOWS
Years ended December 31,


                                                                           1994              1993               1992 
                                                                               (thousands)
<S>                                                                    <C>                <C>                 <C>
Cash flows from operating activities:
Net income                                                             $23,655            $23,884             $19,962
Adjustments to reconcile net income to net cash
provided by operating activities:
Issuance - Policy loans, excluding universal life-type insurance        (1,365)            (1,044)               (635)
Repayment - Policy loans, excluding universal life-type insurance          849                455                 327
Change in accrued investment income                                       (175)            (1,476)             (1,797)
Change in deferred policy acquisition costs, net                       (11,522)           (10,622)            (10,974)
Change in liabilities for future policy benefits for traditional life,
disability income and long-term care insurance                             501               (939)               (855)
Change in policy claims and other policyholders' funds                     870                282                 592
Change in deferred income taxes                                         (4,321)              (449)              1,302
Change in other liabilities                                             (1,711)             4,348                 466
Amortization of premium (accretion of discount), net                     2,464             (1,598)             (1,410)
Net gain on investments                                                   (957)            (1,334)             (2,478)
Premiums related to universal life-type insurance                       19,522             15,141              13,919
Surrenders and death benefits related to universal life-
type insurance                                                         (13,208)            (9,785)             (5,976)
Interest credited to account balances related to universal life-
 type insurance                                                          6,640              6,892               7,168
Policyholder and contractholder charges, non-cash                       (6,000)            (5,663)             (5,452)
Other, net                                                                 689               (780)                700
Net cash provided by operating activities                              $15,931            $17,312             $14,859


See accompanying notes to financial statements.
<PAGE>
PAGE 57
IDS LIFE INSURANCE COMPANY OF NEW YORK
STATEMENTS OF CASH FLOWS (continued)
Years ended December 31,
                                                

                                                                       1994               1993                1992  
                                                                                       (thousands) 
Cash flows from investing activities:
Fixed maturities held to maturity:
Purchases                                                          $  (36,560)           $       -           $        -
Maturities, sinking fund payments and calls                            78,757                    -                    -
Sales                                                                   2,649                    -                    -
Fixed maturities available for sale:
Purchases                                                            (117,965)                   -                    -
Maturities, sinking fund payments and calls                            70,316                    -                    -
Sales                                                                  14,533                    -                    -
Investment securities:
Purchases                                                                   -             (331,900)            (420,607)
Maturities, sinking fund payments and calls                                 -              265,059              210,543
Sales                                                                       -               28,519               67,306
Other investments, excluding policy loans:
Purchases                                                             (47,353)             (65,202)             (19,430)
Sales                                                                   2,975                2,568                  867
Change in amounts due to brokers                                       (4,952)             (10,448)              12,249
Net cash used in investing activities                                 (37,600)            (111,404)            (149,072)

Cash flows from financing activities:
Activity related to investment contracts:
Considerations received                                              168,947               149,269              159,913
Surrenders and death benefits                                       (198,963)             (119,158)             (80,632)
 Interest credited to account balances                                58,378                62,250               61,319
Universal life-type insurance policy loans:
Issuance                                                              (3,907)               (3,403)              (3,668)
Repayment                                                              2,476                 1,886                1,548
Cash dividend to parent                                                    -                     -               (6,000)
Net cash provided by financing activities                             26,931                90,844              132,480


Net increase (decrease) in cash and cash
equivalents                                                            5,262                (3,248)              (1,733)

Cash and cash equivalents at beginning of year                             -                 3,248                4,981

Cash and cash equivalents at end of year                          $    5,262             $       -          $     3,248
                                                                       =====                 =====                =====

See accompanying notes to financial statements.
/TABLE
<PAGE>
PAGE 58
IDS LIFE INSURANCE COMPANY OF NEW YORK
NOTES TO FINANCIAL STATEMENTS
($ thousands)

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
    American Express Financial Corporation (formerly IDS Financial
    Corporation), 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 as reconciled in Note 11.
    
    Investments
    
    As of Jan. 1, 1994, the Company adopted Statement of Financial
    Accounting Standards (SFAS) No. 115, "Accounting for Certain
    Investments in Debt and Equity Securities."  Under SFAS No.
    115, fixed maturities that the Company has both the positive
    intent and the ability to hold to maturity are classified as
    held to maturity and carried at amortized cost.  All other
    fixed maturities and all marketable equity securities are
    classified as available for sale and carried at fair value. 
    Unrealized gains and losses on securities classified as
    available for sale are carried as a separate component of
    stockholder's equity.  The effect of adopting SFAS No. 115 was
    to increase stockholder's equity by approximately $12 million,
    net of tax, as of Jan. 1, 1994, but the adoption had no impact
    on the Company's net income.
    
    Management determines the appropriate classification of fixed
    maturities at the time of purchase and reevaluates the
    classification at each balance sheet date.     
    
    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<PAGE>
PAGE 59
1.  Summary of significant accounting policies (continued)
 
    power of individual investments, such investments are written
    down to the fair 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.
    
    Realized investment gain or loss is determined on an identified
    cost basis.
    
    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:
                                      1994      1993     1992 
    Cash paid during the year for:
      Income taxes                   $17,386  $14,138  $9,193
      Interest on borrowings             147      235     132

    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).  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.

    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.<PAGE>
PAGE 60
1.  Summary of significant accounting policies (continued)

    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
    inrecognition 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 and the 1975-1980 Select and
    Ultimate Basic Table for term insurance policies issued after
    1986), 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 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<PAGE>
PAGE 61
1.  Summary of significant accounting policies (continued)

    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 the1958
    Commissioners Standard Ordinary Mortality Table at 3 percent
    interest for 1980 and prior, 8 percent interest for persons
    disabled from 1981 to 1991, 7.7 percent interest for persons
    disabled in 1992 and 6 percent interest for persons disabled
    after 1992.

    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, 7.7
    percent for claims incurred in 1992 and 6 percent for claims
    incurred after 1992.

    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.

    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 American Express
    Financial Corporation 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 American Express
    Financial Corporation and its subsidiaries that American
    Express Financial Corporation will reimburse a subsidiary for
    any tax benefit.

    Included in other liabilities at Dec. 31, 1994 and 1993 are
    $3,161 and $3,462, respectively, payable to IDS Life for
    federal income taxes.
<PAGE>
PAGE 62
1.  Summary of significant accounting policies (continued)

    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
    contractual insurance rate and that the death benefit will
    never be less than the death benefit at the date of issuance.
       
    Reclassification

    Certain 1993 and 1992 amounts have been reclassified to conform
    to the 1994 presentation.

2.  Investments

    Fair values of investments in fixed maturities represent quoted
    market prices and estimated  values when quoted prices are not
    available.  Estimated 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
    investments for the years ended Dec. 31 are summarized as
    follows:
     
                                1994            1993         1992
         Fixed maturities:
           Held to maturity     $(84,244)      $    --     $    --
           Available for sale    (38,226)           --          --
         Investment securities     --           25,350     (10,980)
<PAGE>
PAGE 63
2.  Investments (continued)

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

                                1994         1993          1992 

        Fixed maturities        $948          $1,316        $2,752
        Other investments          9              18          (274)
                                $957          $1,334        $2,478
                                ====          ======        ======

    The amortized cost, gross unrealized gains and losses and fair
    value of investments in fixed maturities and equity securities
    at Dec. 31, 1994 are as follows:
<TABLE><CAPTION>
                                            Gross            Gross    
                          Amortized       Unrealized       Unrealized          Fair    
Held to maturity           Cost             Gains            Losses            Value  
<S>                       <C>               <C>              <C>
U.S. Government agency
  obligations             $    398          $    2           $    18           $    382
Corporate bonds and
  obligations              622,422           6,564            33,976            595,010
Mortgage-backed
  securities                63,663             580             6,555             57,688
                          $686,483          $7,146           $40,549           $653,080
                           =======           =====            ======            =======  

                                             Gross            Gross
                         Amortized        Unrealized       Unrealized              Fair
Available for sale         Cost              Gains            Losses               Value

U.S. Government agency
  obligations            $  10,000         $     --          $   135           $   9,865
State and municipal
  obligations                  104                1               --                 105
Corporate bonds and
  obligations              142,447            2,632            2,447             142,632
Mortgage-backed
  securities               322,048              381           19,928             302,501
Total fixed maturities     474,599            3,014           22,510             455,103

Equity securities              332               --              197                 135
                          $474,931           $3,014          $22,707            $455,238
                           =======            =====           ====== 
</TABLE>
    The change in net unrealized gain (loss) on available for sale
    securities included as a separate component of stockholder's 
    equity was $(12,393) in 1994.
    
    The amortized cost, gross unrealized gains and losses, and fair
    value of investments in fixed maturities carried at amortized
    cost at Dec. 31, 1993 are as follows:
<PAGE>
PAGE 64
2.  Investments (continued)
<TABLE><CAPTION>
                         Amortized        Unrealized       Unrealized              Fair
1993                       Cost              Gains            Losses               Value
<S>                      <C>               <C>                <C>
U.S. Government agency
  obligations            $    400          $    40            $   --          $      440
State and municipal
  obligations                 105               15                --                 120
Corporate bonds and
  obligations             745,822           60,482             1,858             804,446
Mortgage-backed
  securities              424,696           15,265             4,374             435,587
                       $1,171,023          $75,802            $6,232          $1,240,593
                       ==========          =======            ======          ==========
</TABLE>
    At Dec. 31, 1993, gross and net unrealized appreciation on
    equity securities amounted to $18.  The fair value of equity
    securities was $190 at Dec. 31, 1993.
    
    The amortized cost and fair value of investments in fixed
    maturities at Dec. 31, 1994 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.
<TABLE><CAPTION>
                                          Amortized               Fair   
     Held to maturity                        Cost                 Value  
     <S>                                    <C>                     <C>            
     Due in one year or less                $  4,952                $  5,002
     Due from one to five years               88,837                  89,253 
     Due from five to ten years              386,356                 371,007
     Due in more than ten years              142,675                 130,130
     Mortgage-backed securities               63,663                  57,688
                                            $686,483                $653,080
                                             =======                 =======

                                          Amortized                 Fair   
     Available for sale                     Cost                   Value  
    
     Due from one to five years            $ 92,886               $  93,117 
     Due from five to ten years              37,524                  38,494
     Due in more than ten years              22,141                  20,991
     Mortgage-backed securities             322,048                 302,501
                                           $474,599                $455,103
                                            =======                 =======
</TABLE>
    During the year ended Dec. 31, 1994, fixed maturities
    classified as held to maturity were sold with proceeds of
    $2,649 and gross realized gains and losses on such sales were
    $nil and $86, respectively.  The sale of these fixed maturities
    was due to credit deterioration.
<PAGE>
PAGE 65
2.  Investments (continued)

    In addition, fixed maturities available for sale were sold
    during 1994 with proceeds of $14,533 and gross realized gains
    and losses on such sales were $181 and $308, respectively.
    
    Proceeds from sales of investments in fixed maturities during
    1993 were $28,519.  During 1993,  gross gains of $4,022 and
    gross losses of $2,213 were realized on those sales.
    
    At Dec. 31, 1994, bonds carried at $264 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>
                                            1994       1993        1992  
         <S>                             <C>        <C>         <C>
         Interest on fixed maturities    $  93,800  $ 100,940   $  96,452
         Interest on mortgage loans         13,226      8,424       4,908
         Other investment income             1,219      1,220         841
         Interest on cash equivalents          363         63         378
                                           108,608    110,647     102,579
         Less investment expenses              465        500         508
                                          $108,143   $110,147    $102,071
</TABLE>   
    At Dec. 31, 1994, investments in fixed maturities comprised
    86 percent of the Company's total invested assets.  Securities
    are rated by Moody's and Standard & Poor's (S&P) except for
    securities  carried at approximately $129 million which are
    rated by American Express Financial Corporation internal
    analysts using criteria similar to Moody's and S&P.  A summary
    of investments in fixed maturities, at amortized cost, by
    rating on Dec. 31 is as follows: 
<TABLE><CAPTION>
     Rating                   1994              1993   
     <S>                   <C>              <C>
     Aaa/AAA               $  393,736       $   425,404
     Aa/AA                     18,857            13,285
     Aa/A                       9,710            14,213
     A/A                      191,694           139,878
     A/BBB                     57,206            62,817
     Baa/BBB                  340,271           343,233
     Baa/BB                    48,552            55,812
     Below investment grade   101,056           116,381
                           $1,161,082        $1,171,023
                           ==========        ==========
</TABLE>
    At Dec. 31, 1994, 93 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 percent of the
    Company's total investments in fixed maturities. 
<PAGE>
PAGE 66
2.  Investments (continued)
       
    At Dec. 31, 1994, approximately 12.5 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, 1994                Dec. 31, 1993      
                                      On Balance    Commitments    On Balance    Commitments
      Region                            Sheet       to Purchase      Sheet       to Purchase
      <S>                             <C>               <C>        <C>            <C>
      West North Central              $  26,660         $ --       $  27,349      $  1,713
      East North Central                 35,018           --          28,349         2,569
      South Atlantic                     39,516           18          26,423         8,279
      Middle Atlantic                    24,061           --          15,912         8,564
      Pacific                            13,297           --          12,224            --
      Mountain                           15,218           --           6,723         4,568
      New England                         9,674           --           4,858         2,855
      East South Central                  1,629           --           1,646            --
      West South Central                    288           --             298            --
                                        165,361           18         123,782        28,548
      Less allowance for losses             445           --             445            --   
                                       $164,916          $18        $123,337       $28,548
                                        =======           ==         =======

                                       Dec. 31, 1994                Dec. 31, 1993      
                                      On Balance    Commitments    On Balance    Commitments
      Region                            Sheet       to Purchase      Sheet       to Purchase
      Apartments                       $  65,389         $18        $ 47,178       $15,130
      Department/retail stores            57,608          --          38,253         9,706 
      Office buildings                    13,107          --          11,475         1,142
      Industrial buildings                13,583          --          13,781         1,142
      Medical buildings                    6,704          --           5,229         1,428
      Nursing/retirement                   6,644          --           5,507            --
      Other                                2,038          --           2,061            --
      Hotels/motels                          288          --             298            --
                                         165,361          18         123,782        28,548 
      Less allowance for losses              445          --             445            --
                                        $164,916         $18        $123,337       $28,548
                                         =======          ==        ======== 
</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.
<PAGE>
PAGE 67
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:
<TABLE><CAPTION>
                                           1994       1993        1992  
    <S>                                   <C>        <C>        <C>
    Federal income taxes:
         Current                          $16,419    $13,164    $  9,037
         Deferred                          (4,320)      (449)      1,302
                                           12,099     12,715      10,339

      State income taxes-current              695        620         575
      Income tax expense                  $12,794    $13,335     $10,914
                                            =====      =====       =====
</TABLE>
      Increases (decreases) to the federal tax provision applicable
to pretax income based on the statutory rate are attributable to:

<TABLE><CAPTION>
                                       1994                   1993                   1992        
                                      Provision  Rate        Provision  Rate        Provision  Rate
      <S>                             <C>        <C>         <C>        <C>
      Federal income taxes based
       on the statutory rate          $12,757    35.0%       $13,026    35.0%       $10,498    34.0%
      Increases (decreases)
       are attributable to:
        Tax-excluded interest
          and dividend income            (554)   (1.5)          (557)   (1.5)          (429)   (1.4)
        Other, net                       (104)   (0.3)           246     0.7            270     0.9
      Federal income taxes            $12,099    33.2%       $12,715    34.2%       $10,339    33.5%
                                       ======     ===          =====     ===          =====     ===
</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, 1994, 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.
<PAGE>
PAGE 68
3.    Income taxes (continued)

    Significant components of the Company's deferred tax assets and
    liabilities as of Dec. 31  are as follows:
<TABLE><CAPTION>
                                                 1994       1993  
       <S>                                       <C>        <C> 
       Deferred tax assets:
        Policy reserves                          $21,567    $15,683
        Investments                                3,331         --
        Other                                      2,991      1,543
          Total deferred tax assets               27,889     17,226


        Deferred tax liabilities:
        Deferred policy acquisition costs         29,933     27,250
        Investments                                   --      2,994
          Total deferred tax
            liabilities                           29,933     30,244
          Net deferred tax liabilities           $ 2,044    $13,018
                                                   =====      =====
</TABLE>
    The Company is required to establish a "valuation allowance"
    for any portion of the deferred tax assets that management
    believes will not be realized.  In the opinion of management,
    it is more likely than not that the Company will realize the
    benefit of the deferred tax assets, and, therefore, no such
    valuation allowance has been established.

4.      Stockholder's equity

    Retained earnings available for distribution as dividends to
    the 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 $70,974 as of Dec. 31, 1994 and $52,642 as of Dec.
    31, 1993 (see Note 3 with respect to the income tax effect of
    certain distributions).  In addition, any dividend
    distributions in 1994 in excess of approximately $7,097 would
    require approval of the New York Insurance Department.    

    Dividends paid to parent were $nil in 1994, $nil in 1993 and
    $6,000 in 1992.
    
5.  Retirement plan and services

    The Company participates in the retirement plan of American
    Express Financial Corporation which covers all permanent
    employees age 21 and over who have met certain employment
    requirements.  The benefits are based on years of service and
    the employee's monthly average of basic annual salary rates in
    effect on January 1, or such other date as determined by
    American Express Financial Corporation, of the highest five
    consecutive annual salaries of the last 10 years.  American
    Express Financial Corporation's 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 1994, 1993 and 1992.<PAGE>
PAGE 69
5.  Retirement plan and services (continued)

    The Company has a "Sales Benefit Plan" which is an unfunded,
    noncontributory retirement plan for all eligible financial
    advisors.  Total plan costs for 1994, 1993 and 1992, which are
    calculated on the basis of commission earnings of the
    individual financial advisors, were $1,372, $1,042 and $1,164,
    respectively.  Such costs are included in deferred policy
    acquisition costs.
    
    The Company also participates in defined contribution pension
    plans of American Express Financial Corporation 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 1994, 1993 and 1992
    were $251, $201 and $144, respectively.

    The Company participates in defined benefit health care plans
    of American Express Financial Corporation that provide health
    care and life insurance benefits to retired employees and
    retired financial advisors.  The plans include participant
    contributions and service-related eligibility requirements. 
    Upon retirement, such employees are considered to have been
    employees of American Express Financial Corporation.  American
    Express Financial  Corporation 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.  At Dec. 31, 1994, the total
    accumulated post retirement benefit obligation, determined in
    accordance with SFAS 106 and based on an assumed interest rate
    of 8.75 percent and a health care cost trend rate of 7 percent,
    has been recorded as a liability by American Express Financial
    Corporation.

6.  Incentive plan and operating expenses

    The Company maintains a "Persistency Payment Plan."  Under the
    terms of this plan, financial advisors earn additional
    compensation based on the volume and persistency of insurance
    sales.  The total costs for the plan for 1994, 1993 and 1992
    were $1,287, $1,387 and $1,252, respectively.  Such costs are
    included in deferred policy acquisition costs.

    Charges by IDS Life and American Express Financial Corporation
    for the use of joint facilities, marketing services and other
    services aggregated $9,314, $7,421 and $6,914 for 1994, 1993
    and 1992, respectively.  Certain of the costs assessed to the
    Company are included in deferred policy acquisition costs.
<PAGE>
PAGE 70
7.  Commitments and contingencies

    At Dec. 31, 1994 and 1993, traditional life insurance and
    universal life-type insurance in force aggregated $3,155,571
    and $2,933,830, respectively, of which $162,956 and $172,973
    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 $76, $67 and $60 for the years ended Dec. 31, 1994, 1993 and
    1992, respectively.  Claim recoveries under the terms of this
    reinsurance agreement were $nil in 1994, $nil in 1993 and $534
    in 1992.

    Premiums ceded to reinsurers other than IDS Life amounted to
    $721, $741 and $773 for the years ended Dec. 31, 1994, 1993 and
    1992, respectively.  Reinsurance recovered from reinsurers
    other than IDS Life amounted to $14, $379 and $186 for the
    years ended Dec. 31, 1994, 1993 and 1992. 

    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 $447,317 and $512,555 at Dec. 31,
    1994 and 1993, respectively.  The accompanying statement of
    income includes premiums of $nil for the years ended Dec. 31,
    1994, 1993 and 1992, and decrease in liabilities for future
    policy benefits of $2,538, $3,032 and $3,825 related to this
    agreement for the years ended Dec. 31, 1994, 1993 and 1992,
    respectively.
    
8.  Lines of credit

    The Company has available lines of credit with two banks
    aggregating $30,000 at 40 to 80 basis points over each bank's
    cost of funds.  Outstanding borrowings under these agreements
    were $nil and $1,519 at Dec. 31, 1994 and 1993, respectively.

9.  Derivative financial instruments

    The Company enters into transactions  involving derivative
    financial instruments to manage its exposure to interest rate
    risk, including hedging specific transactions.  The Company
    manages risks associated with these instruments as described
    below.  The Company does not hold derivative instruments for
    trading purposes.

    Market risk is the possibility that the value of the derivative
    financial instruments will change due to fluctuations in a
    factor from which the instrument derives<PAGE>
PAGE 71
9.  Derivative financial instruments (continued)

    its value, primarily an interest rate.  The Company is not
    impacted by market risk related to derivatives held for non-
    trading purposes beyond that inherent in cash market
    transactions.  Derivatives held for purposes other than trading
    are largely used to manage risk and, therefore, the cash flow
    and income effects of the derivatives are inverse to the
    effects of the underlying transactions. 

    Credit risk is the possibility that the counterparty will not
    fulfill the terms of the contract.  The Company monitors credit
    exposure related to derivative financial instruments through
    established approval procedures, including setting
    concentration limits by counterparty and industry, and
    requiring collateral, where appropriate.  A vast majority of
    the Company's counterparties are rated A or better by Moody's
    and Standard & Poor's.

    The notional or contract amount of a derivative financial
    instrument is generally used to calculate the cash flows that
    are received or paid over the life of the agreement.  Notional
    amounts are not recorded on the balance sheet.  Notional
    amounts far exceed the related credit exposure.

    Credit exposure related to interest rate caps is measured by 
    carrying value of the contracts.
<TABLE><CAPTION>
                                             Notional     Carrying     Fair     Total Credit
         Assets                               Amount      Value       Value     Exposure     
         <S>                                  <C>           <C>         <C>        <C>
         Interest rate caps                   $200,000      $1,389      $828       $1,389
</TABLE>
    The fair values of derivative financial instruments are based
    on market values, dealer quotes or pricing models.  The
    interest rate caps expire on various dates from 1996 to 1997.

    Interest rate caps are used to manage the Company's exposure to
    rising interest rates.  These instruments are used primarily to
    protect the margin between interest rate earned on investments
    and the interest rate credited to related annuity contract
    holders.

    The cost of interest rate caps is amortized to interest expense
    over the life of the contracts and payments received as a
    result of these agreements are recorded as a reduction of
    interest expense when realized.  The amortized cost of interest
    rate cap contracts is included in other investments.
    
10.     Fair values of financial instruments

    The Company is required to disclose fair value information for
    most on- and off-balance sheet financial instruments for which
    it is practical to estimate that value.  Certain financial
    instruments such as life insurance obligations,<PAGE>
PAGE 72
10.     Fair values of financial instruments (continued)

    receivables and all non-financial instruments, such as deferred
    acquisition costs are excluded from required disclosure.  Off-
    balance sheet intangible assets, such as the value the field
    force, are also excluded.  Management believes the value of
    excluded assets is significant.  The fair value of the Company,
    therefore, cannot be estimated by aggregating the amounts
    presented.
<TABLE><CAPTION>

                                       1994                              1993              
                                    Carrying      Fair                  Carrying      Fair   
        Financial Assets            Value         Value                 Value         Value  
        <S>                         <C>           <C>                   <C>           <C>
        Investments:
        Fixed maturities (Note 2):
          Held to maturity          $686,483      $653,080              $     --      $    --
          Available for sale         455,103       455,103                    --           --
          Investment securities           --            --               1,171,023     1,240,593
        Mortgage loans on
          real estate (Note 2)       164,916       157,085                 123,337       124,030
        Other:
          Equity securities (Note 2)     135           135                     190           190
          Derivative financial
            instruments (Note 9)       1,389           828                   2,050           385
        Cash and
          cash equivalents (Note 1)    5,262         5,262                      --            --
        Assets held in segregated
          asset accounts (Note 1)    506,208       506,208                 380,796       380,796

      Financial Liabilities
         Future policy benefits
           for fixed annuities     1,025,881       991,358               1,003,009       970,169
         Liabilities related to
           segregated asset accounts 474,958       448,665                 357,176       339,122
</TABLE>
    At Dec. 31, 1994 and 1993, the carrying amount and fair value
    of future policy benefits for fixed annuities exclude life
    insurance-related contracts carried at $59,803 and $54,911,
    respectively, and policy loans of $1,683 and $1,085 at Dec. 31,
    1994 and 1993, respectively.  The fair value of these benefits
    is based on the status of the annuities at Dec. 31, 1994 and
    1993.  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 1994
    and 1993. 

    At Dec. 31, 1994 and 1993 the fair value of liabilities related
    to segregated asset accounts is estimated as the carrying
    amount less variable insurance contracts carried at $31,250 and
    $23,620, respectively, and surrender charges, if applicable. 
<PAGE>
PAGE 73
11.      Statutory insurance accounting practices

    Reconciliations of net income for 1994, 1993 and 1992 and
    stockholder's equity at Dec. 31, 1994 and 1993, as shown in the
    accompanying financial statements, to that determined using 
    statutory accounting practices are as follows:
<TABLE><CAPTION>
                                             1994          1993             1992  
         <S>                               <C>           <C>             <C>
         Net income, per accompanying
           financial statements            $23,655       $23,884         $19,962
         Deferred policy acquisition costs (12,187)      (10,622)        (10,974)
         Adjustments of future policy
           benefit liabilities              13,741        13,597           9,319
         Deferred federal income taxes      (4,321)         (462)          1,302
         Provision for losses on investments(1,652)          438          (2,279)
         Separate account gains                142         2,708           4,234
         Other, net                            755        (1,182)         (1,757)
         Net income, on basis of
           statutory accounting practices  $20,133       $28,361         $19,807
                                             =====         =====           =====
</TABLE>
<TABLE><CAPTION>

                                                    1994           1993   
         <S>                                       <C>           <C>
         Stockholder's equity, per accom-
           panying financial statements            $171,721      $160,459
         Deferred policy acquisition costs         (100,078)      (87,891)
         Adjustments of future policy                         
           benefit liabilities                       33,827        20,086
         Deferred federal income taxes                2,044        13,018 
         Securities valuation reserve               (15,939)      (12,780) 
         Adjustments of separate account liabilities 13,557        13,415
         Net unrealized loss on investments          19,497            --
         Premiums due                                   851           856 
         Deferred revenue liability                     834           895
         Book value adjustment of bonds                  --        (1,918)
         Allowance for losses                           445         2,097
         Non-admitted assets                           (503)         (552)
         Interest maintenance reserve                (2,110)       (2,056)
         Other, net                                     249          (144)
         Stockholder's equity, on basis of
           statutory accounting practices          $124,395      $105,485 
                                                     ======        ======
/TABLE
<PAGE>
PAGE 74
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, 1994 and 1993, and the
related statements of income and cash flows for each of the three
years in the period ended December 31, 1994.  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, 1994 and 1993,
and the results of its operations and its cash flows for each of
the three years in the period ended December 31, 1994, in
conformity with generally accepted accounting principles. 

As discussed in Note 1 to the financial statements, the Company
changed its method of accounting for certain investments in debt
and equity securities in 1994.




Ernst & Young LLP

February 3, 1995
Minneapolis, Minnesota  

<PAGE>
PAGE 75
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, 10, 11, 5, 6 and 9:

          Statements of Net Assets at Dec. 31, 1994.
          Statements of Operations for the year ended Dec. 31, 
            1994.
          Statements of Changes in Net Assets for the years ended
            Dec. 31, 1994 and Dec. 31, 1993.
          Notes to Financial Statements.
          Report of Independent Auditors dated March 17, 1995.

     IDS Life Insurance Company of New York:

          Balance Sheets at Dec. 31, 1994 and 1993;
          Statements of Income for the years ended Dec. 31, 1994,
           1993, and 1992;
          Statements of Cash Flows for the years ended Dec. 31,
          1994,     1993, and 1992;
          Notes to Financial Statements.
          Report of Independent Auditors dated February 3, 1995.

(b)  Exhibits:

1.1  Resolution of the Executive Committee of the Board of
     Directors of IDS Life of New York dated Nov. 12, 1981, 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, filed electronically
     as Exhibit 1.2 to Post-Effective Amendment No. 20 to
     Registration Statement No. 2-73114, is incorporated herein by
     reference.

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, 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, 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), filed electronically as Exhibit 4.1 to Post-Effective
     Amendment No. 20 to Registration Statement No. 2-73114, is
     incorporated herein by reference.
<PAGE>
PAGE 76
4.2  Copy of form of Non-Qualified Deferred Annuity Contract (form
     39191), filed electronically as Exhibit 4.2 to Post-Effective
     Amendment No. 21 to Registration Statement No. 2-78194, is
     incorporated herein by reference.

4.3  Copy of form of Deferred Annuity Contract (IRA) (form 39192
     IRA), filed electronically as Exhibit 4.3 to Post-Effective
     Amendment No. 21 to Registration Statement No. 2-78194, is
     incorporated herein by reference.

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, 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 as Exhibit 6.1 to Post-Effective
     Amendment No. 21 to Registration Statement No. 2-78194, is
     incorporated herein by reference.

6.2  By-Laws of IDS Life of New York dated May, 1992, filed
     electronically as Exhibit 6.2 to Post-Effective Amendment No.
     21 to Registration Statement No. 2-78194, is incorporated
     herein by reference.

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 28, 1995.

10.  Consent of Independent Auditors is filed electronically
     herewith.

11.  Financial Statement Schedules I, III, IV, and V as required by
     Regulation S-X:  (filed electronically herewith)
     
          Schedule I - Summary of Investments Other than
          Investments
                     in Related Parties as of Dec. 31, 1994
          Schedule III - Supplementary Insurance Information for
     the
                       years ended Dec. 31, 1994, 1993 and 1992
          Schedule IV - Reinsurance for the years ended Dec. 31,
                      1994, 1993 and 1992
          Schedule V - Valuation and Qualifying Accounts for the
                     years ended Dec. 31, 1994, 1993 and 1992
          Report of Independent Auditors dated February 3, 1995.

     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.<PAGE>
PAGE 77
12.  Not applicable.

13.  Not applicable.

14.  Financial Data Schedule, filed electronically herewith.

14.  Power of Attorney, dated April 18, 1994, filed electronically
     as Exhibit 14.2 to Post-Effective Amendment No. 21 to
     Registration Statement No. 2-78194, is incorporated herein by
     reference.
<TABLE><CAPTION>
Item 25.  Directors and Officers of the Depositor (IDS Life
          Insurance Company of New York)

                                                        Positions and
Name                     Principal Business Address     Offices with Depositor
<S>                      <C>                            <C>
Mario Alaia              20 Madison Avenue Extension    Claims Officer and
                         Albany, NY                       Assistant Secretary

Tracy A. Anderson        IDS Tower 10                   Treasurer and Chief Actuary
                         Minneapolis, MN  55440

Darrell C. Beckstrom     IDS Tower 10                   Underwriting Officer
                         Minneapolis, MN  55440

John C. Boeder           20 Madison Avenue Extension    Director
                         Albany, NY

Michael B. Carlin        20 Madison Avenue Extension    General Counsel and
                         Albany, NY                       Secretary

Roger C. Corea           20 Madison Avenue Extension    Director
                         Albany, NY

Charles A. Cuccinello    20 Madison Avenue Extension    Director
                         Albany, NY

Milton R. Fenster        20 Madison Avenue Extension    Director
                         Albany, NY

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

Lorraine R. Hart         IDS Tower 10                   Investment Officer
                         Minneapolis, MN  55440

Robert A. Hatten         IDS Tower 10                   Director, Vice
                         Minneapolis, MN  55440           President and Chief
                                                          Operating Officer

Richard W. Kling         IDS Tower 10                   Director, Chairman of
                         Minneapolis, MN  55440           the Board and President

Edward Landes            IDS Tower 10                   Director
                         Minneapolis, MN  55440
<PAGE>
PAGE 78
Item 25.  Directors and Officers of the Depositor (IDS Life Insurance Company of New York)
            (continued)
                                                        Positions and
Name                     Principal Business Address     Offices with Depositor
Janis E. Miller          IDS Tower 10                   Executive Vice President
                         Minneapolis, MN  55440

Michael P. Monaco        World Financial Center         Director
                         New York, NY  

Stephen P. Norman        World Financial Center         Director
                         New York, NY  

Kevin E. Palmer          IDS Tower 10                   Reinsurance Actuary
                         Minneapolis, MN  55440

Louise M. Parent         World Financial Center         Director
                         New York, NY

Carl N. Platou           IDS Tower 10                   Director
                         Minneapolis, MN  55440

Gordon H. Ritz           404 WCCO Radio Bldg.           Director
                         Minneapolis, MN  

F. Dale Simmons          IDS Tower 10                   Vice President and
                         Minneapolis, MN  55440           Assistant Treasurer

William A. Stoltzmann    IDS Tower 10                   Counsel and Assistant
                         Minneapolis, MN  55440           Secretary

Michael R. Woodward      20 Madison Avenue Extension    Director
                         Albany, NY
</TABLE>
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 American Express Financial
          Corporation.  American Express 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<PAGE>
PAGE 79
III. Companies engaged in Investors Diversified Financial Services

     American Centurion Life Insurance Company      New York
     American Enterprise Investment Services Inc.   Minnesota
     American Enterprise Life Insurance Company     Indiana
     American Express Financial Advisors Inc.       Delaware
     American Express Financial Corporation         Delaware
     American Express Minnesota Foundation          Minnesota
     American Express Service Corporation           Delaware
     American Express Tax and Business Services     Minnesota
     American Express Trust Company                 Minnesota
     American Partners Life Insurance Company       Arizona
     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 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
     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
     Investors Syndicate Development Corp.          Nevada

Item 27.  Number of Contractowners

          On March 31, 1995, there were 1,928 contract owners of
          qualified Combination Retirement Annuity contracts. 
          There were no owners of non-qualified contracts.

          There were 36 owners of qualified Variable Retirement
          Annuity contracts.  There were 288 owners of non-
          qualified contracts.
<PAGE>
PAGE 80
Item 28.  Indemnification

          The By-Laws of the depositor provide that it shall
          indemnify any person made, or threatened to be made, a
          party to an action, suit or proceeding, civil or
          criminal, by reason of the fact that he, his testator or
          intestate, is or was a 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
          judgments, 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.

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)  American Expess Financial Advisors Inc. (formerly IDS
     Financial Services Inc.) acts as principal underwriter
     for the following investment companies:

     IDS Bond Fund, Inc.; IDS California Tax-Exempt Trust; IDS
     Discovery Fund, Inc.; IDS Equity Select Fund, Inc.; IDS Extra
     Income Fund, Inc.; IDS Federal Income Fund, Inc.; IDS Global
     Series, Inc.; IDS Growth Fund, Inc.; IDS High Yield Tax-Exempt
     Fund, Inc.; IDS International Fund, Inc.; IDS Investment
     Series, Inc.; IDS Managed Retirement Fund, Inc.; IDS Market<PAGE>
PAGE 81
Item 29.     Principal Underwriters. (continued)

     Advantage Series, Inc.; IDS Money Market Series, Inc.; IDS New
     Dimensions Fund, Inc.; IDS Precious Metals Fund, Inc.; IDS
     Progressive Fund, Inc.; IDS Selective Fund, Inc.; IDS Special
     Tax-Exempt Series Trust; 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.

(b)   As to each director, officer or partner of the principal
      underwriter:
<TABLE><CAPTION>                                                    
                                                     Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   
<S>                      <C>                          <C>
Ronald G. Abrahamson     Vice President-              None
IDS Tower 10             Service Quality and
Minneapolis, MN 55440    Reengineering

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

Jerome R. Amundson       Vice President-              None
IDS Tower 10             Investment Accounting
Minneapolis, MN 55440

Peter J. Anderson        Senior Vice President-       None
IDS Tower 10             Investments
Minneapolis, MN 55440

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

Alvan D. Arthur          Group Vice President-        None
IDS Tower 10             Central California/
Minneapolis, MN  55440   Western Nevada

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

Robert C. Basten         Vice President-Tax           None
IDS Tower 10             and Business Services
Minneapolis, MN  55440
<PAGE>
PAGE 82
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

Timothy V. Bechtold      Vice President-Risk          None
IDS Tower 10             Management Products
Minneapolis, MN  55440

John D. Begley           Group Vice President-        None
Suite 100                Ohio/Indiana
7760 Olentangy River Rd.
Columbus, OH  43235
Carl E. Beihl            Vice President-              None
IDS Tower 10             Strategic Technology
Minneapolis, MN 55440    Planning

Jack A. Benjamin         Group Vice President-        None
Suite 200                Greater Pennsylvania
3500 Market Street
Camp Hill, PA  17011

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

Brent L. Bisson          Group Vice President-        None
Ste 900 e Westside Tower Los Angeles Metro
11835 West Olympic Blvd.
Los Angeles, CA  90064

John C. Boeder           Vice President-              None
IDS Tower 10             Mature Market Group
Minneapolis, MN  55440

Bruce J. Bordelon        Group Vice President-        None
Galleria One Suite 1900  Gulf States
Galleria Blvd.
Metairie, LA  70001

Charles R. Branch        Group Vice President-        None
Suite 200                Northwest
West 111 North River Dr
Spokane, WA  99201

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

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

<PAGE>
PAGE 83
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

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

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

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

James E. Choat           Senior Vice President-       None
IDS Tower 10             Field Management
Minneapolis, MN  55440

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           Group Vice President-        None
290 Woodcliff Drive      Upstate New York
Fairport, NY  14450

Henry J. Cormier         Group Vice President-        None
Commerce Center One      Connecticut
333 East River Drive
East Hartford, CT  06108

John M. Crawford         Group Vice President-        None
Suite 200                Arkansas/Springfield/Memphis
10800 Financial Ctr Pkwy
Little Rock, AR  72211

Kevin F. Crowe           Group Vice President-        None
Suite 312                Carolinas/Eastern Georgia
7300 Carmel Executive Pk
Charlotte, NC  28226

Alan R. Dakay            Vice President-              None
IDS Tower 10             Institutional Products
Minneapolis, MN 55440    Group

Regenia David            Vice President-              None
IDS Tower 10             Systems Services
Minneapolis, MN  55440
<PAGE>
PAGE 84
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

Scott M. Digiammarino    Group Vice President-        None
Suite 500                Washington/Baltimore
8045 Leesburg Pike
Vienna, VA  22182

Bradford L. Drew         Group Vice President-        None
Two Datran Center        Eastern Florida
Penthouse One B
9130 S. Dadeland Blvd.
Miami, FL  33156

William H. Dudley        Director and Executive       None
IDS Tower 10             Vice President-
Minneapolis MN 55440     Investment Operations

Roger S. Edgar           Senior Vice President        None
IDS Tower 10             and Technology Advisor
Minneapolis, MN 55440

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

Robert M. Elconin        Vice President-              None
IDS Tower 10             Government Relations
Minneapolis, MN  55440

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

Joseph Evanovich Jr.     Group Vice President-        None
One Old Mill             Nebraska/Iowa/Dakotas
101 South 108th Avenue
Omaha, NE  68154

Louise P. Evenson        Group Vice President-        None
Suite 200                San Francisco Bay Area
1333 N. California Blvd.
Walnut Creek, CA  94596

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

Louis C. Fornetti        Senior Vice President        Vice
IDS Tower 10             and Chief Financial          President
Minneapolis, MN 55440    Officer
<PAGE>
PAGE 85
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

Douglas L. Forsberg      Group Vice President-        None
Suite 100                Portland/Eugene
7931 N. E. Halsey
Portland, OR  97213

William P. Fritz         Group Vice President-        None
Suite 160                Northern Missouri
12855 Flushing Meadows Dr
St. Louis, MO  63131

Carl W. Gans             Group Vice President-        None
8500 Tower Suite 1770    Twin City Metro
8500 Normandale Lake Blvd.
Bloomington, MN  55437

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           Vice
IDS Tower 10             Corporate Treasurer          President &
Minneapolis, MN 55440                                 Treasurer

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

Bruce M. Guarino         Group Vice President-        None
Suite 1736               Hawaii
1585 Kapiolani Blvd.
Honolulu, HI  96814

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

Teresa A. Hanratty       Group Vice President-        None
Suites 6&7               Northern New England
169 South River Road
Bedford, NH  03110

John R. Hantz            Group Vice President-        None
Suite 107                Detroit Metro
17177 N. Laurel Park
Livonia, MI  48154<PAGE>
PAGE 86
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

Robert L. Harden         Group Vice President-        None
Two Constitution Plaza   Boston Metro
Boston, MA  02129

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

Scott A. Hawkinson       Vice President-Assured       None
IDS Tower 10             Assets Product Development
Minneapolis, MN 55440    and Management

Brian M. Heath           Group Vice President-        None
Suite 250                North Texas
801 E. Campbell Road
Richardson, TX  75081

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

David J. Hockenberry     Group Vice President-        None
30 Burton Hills Blvd.    Eastern Tennessee
Suite 175
Nashville, TN  37215

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 L. Johns        Senior Vice President-       None
IDS Tower 10             Field Management
Minneapolis, MN 55440

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

James E. Kaarre          Vice President-              None
IDS Tower 10             Marketing Information
Minneapolis, MN  55440<PAGE>
PAGE 87
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)
                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

Linda B. Keene           Vice President-              None
IDS Tower 10             Market Development
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         Senior Vice President-       Director,
IDS Tower 10             Risk Management Products     Chairman &
Minneapolis, MN  55440                                President

Paul F. Kolkman          Vice President-              None
IDS Tower 10             Actuarial Finance
Minneapolis, MN 55440

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

David S. Kreager         Group Vice President-        None
Ste 108 Trestle Bridge V Greater Michigan
5136 Lovers Lane
Kalamazoo, MI  49002

Steven C. Kumagai        Director and Senior          None
IDS Tower 10             Vice President-Field
Minneapolis, MN 55440    Management and Business
                         Systems

Mitre Kutanovski         Group Vice President-        None
Suite 680                Chicago Metro
8585 Broadway
Merrillville, IN  48410

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

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

Lori J. Larson           Vice President-              None
IDS Tower 10             Variable Assets Product
Minneapolis, MN  55440   Development<PAGE>
PAGE 88
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

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

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

Richard J. Lazarchic     Vice President-              None
IDS Tower 10             Senior Portfolio 
MInneapolis, MN  55440   Manager

Peter A. Lefferts        Senior Vice President-       None
IDS Tower 10             Corporate Strategy and
Minneapolis, MN  55440   Development

Douglas A. Lennick       Director and Executive       None
IDS Tower 10             Vice President-Private
Minneapolis, MN  55440   Client Group

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

Fred A. Mandell          Vice President-              None
IDS Tower 10             Field Marketing Readiness
Minneapolis, MN  55440

Daniel E. Martin         Group Vice President-        None
Suite 650                Pittsburgh Metro
5700 Corporate Drive
Pittsburgh, PA  15237

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-              Director
IDS Tower 10             Variable Assets
Minneapolis, MN 55440<PAGE>
PAGE 89
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)
                                                      Positions and
Name and Principal       Position and Offices         Offices with
Business Address         with Underwriter             Registrant   

James A. Mitchell        Executive Vice President-    None
IDS Tower 10             Marketing and Products
Minneapolis, MN 55440

John P. Moraites         Group Vice President-        None
Union Plaza Suite 900    Kansas/Oklahoma
3030 Northwest Expressway
Oklahoma City, OK  73112

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

Barry J. Murphy          Senior Vice President-       None
IDS Tower 10             Client Service
Minneapolis, MN  55440

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

Ronald E. Newton         Group Vice President-        None
319 Southbridge St.      Rhode Island/Central
Auburn, MA  01501        Massachusetts

Thomas V. Nicolosi       Group Vice President-        None
Suite 220                New York Metro Area
500 Mamaronick Avenue
Harrison, NY  10528

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

Carla P. Pavone          Vice President-              None
IDS Tower 10             Specialty Service Teams
Minneapolis, MN  55440   and Emerging Business

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             Segmentation Development
Minneapolis, MN 55440    and Support

Larry M. Post            Group Vice President-        None
One Tower Bridge         Philadelphia Metro
100 Front Street 8th Fl
West Conshohocken, PA  19428<PAGE>
PAGE 90
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

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

R. Daniel Richardson     Group Vice President-        None
Suite 800                Southern Texas
Arboretum Plaza One
9442 Capital of Texas Hwy N.
Austin, TX  78759

Roger B. Rogos           Group Vice President-        None
One Sarasota Tower       Western Florida
Suite 700
Two N. Tamiami Trail
Sarasota, FL  34236

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

Max G. Roth              Group Vice President-        None
Suite 201 S IDS Ctr      Wisconsin/Upper Michigan
1400 Lombardi Avenue
Green Bay, WI  54304

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

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

Erven A. Samsel          Senior Vice President-       None
IDS Tower 10             Field Management
Minneapolis, MN  55440
<PAGE>
PAGE 91
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

Russell L. Scalfano      Group Vice President-        None
Suite 201 Exec Pk East   Illinois/Indiana/Kentucky
101 Plaza East Blvd.
Evansville, IN  47715

William G. Scholz        Group Vice President-        None
Suite 205                Arizona/Las Vegas
7333 E Doubletree Ranch Rd
Scottsdale, AZ  85258

Stuart A. Sedlacek       Vice President-              None
IDS Tower 10             Assured Assets
Minneapolis, MN  55440

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         Group Vice Presidnet-        None
Ste 1700 Orlando FinCtr  Orlando/Jacksonville
800 North Magnolia Ave.
Orlando, FL  32803

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

William A. Smith         Vice President and           None
IDS Tower 10             Controller-Private
Minneapolis, MN 55440    Client Group

James B. Solberg         Group Vice President-        None
IDS Tower 10             Eastern Iowa Area
Minneapolis, MN 55440

Bridget Sperl            Vice President-              None
IDS Tower 10             Human Resources
Minneapolis, MN 55440    Management Services
<PAGE>
PAGE 92
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

Paul J. Stanislaw        Group Vice President-        None
Suite 1100               Southern California
Two Park Plaza
Irvine, CA  92714

Lois A. Stilwell         Group Vice President-        None
Suite 433                Outstate Minnesota Area/
9900 East Brn Road       North Dakota/Western Wisconsin
Minnetonka, MN  55343

William A. Stoltzmann    Vice President and           Gen'l Counsel
IDS Tower 10             Assistant General            & Asst. Secry
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           Group Vice President-        None
Suite 425                Seattle/Tacoma
101 Elliott Avenue West
Seattle, WA  98119

John R. Thomas           Senior Vice President-       None
IDS Tower 10             Information and
Minneapolis, MN 55440    Technology

Melinda S. Urion         Vice President and           Assistant
IDS Tower 10             Corporate Controller         Secretary
Minneapolis, MN 55440

Peter S. Velardi         Group Vice President-        None
Suite 180                Atlanta/Birmingham
1200 Ashwood Parkway
Atlanta, GA  30338

Charles F. Wachendorfer  Group Vice President-        None
Suite 100                Denver/Salt Lake City/
Stanford Plaza II        Albuquerque
7979 East Tufts Ave Pkwy
Denver, CO  80237

Wesley W. Wadman         Vice President-              None
IDS Tower 10             Senior Portfolio
Minneapolis, MN 55440    Manager<PAGE>
PAGE 93
Item 29(b).  As to each director, officer or partner of the
principal underwriter (American Express Financial Advisors):
(cont'd)

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

Norman Weaver Jr.        Senior Vice President-       None
1010 Main St Suite 2B    Field Management
Huntington Beach, CA  92648

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

Jeffry M. Welter         Vice President-              None
IDS Tower 10             Equity and Fixed Income
Minneapolis, MN  55440   Trading

William N. Westhoff      Senior Vice President and    None
IDS Tower 10             Global Chief Investment
Minneapolis, MN  55440   Officer

Thomas L. White          Group Vice President-        None
Suite 200 Cambridge Ct   Cleveland Metro
28601 Chagrin Blvd.
Woodmere, OH  44122

Eric S. Williams         Group Vice President-        None
Suite 250                Virginia
3951 Westerre Parkway
Richmond, VA  23233

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

Michael R. Woodward      Senior Vice President-       None
32 Ellicott St Ste 100   Field Management
Batavia, NY  14020
</TABLE>
<TABLE><CAPTION>
(c) Name of          Net Underwriting
    Principal        Discounts and      Compensation on    Brokerage     Other
    Underwriter      Commissions           Redemption      Commissions   Compensation
    <S>                  <C>            <C>                   <C>            <C>    
    American Express
    Financial
    Advisors Inc.        None           $269,275.10           None           None
</TABLE>
* Surrender charges received by IDS Life of New York.
<PAGE>
PAGE 94
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 95
                            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 485(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 27th day of April, 1995.

                                     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 27th day of April, 1995.

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 96
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
electronically as Exhibit 14.2 to Post-Effective Amendment No. 21
to Registration Statement No. 2-78194.



/s/  Mary Ellyn Minenko    
Mary Ellyn Minenko 
<PAGE>
PAGE 97
             CONTENTS OF REGISTRATION STATEMENT NO. 22

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.

<PAGE>
PAGE 1

IDS Life of New York Accounts 4, 5, 6, 9, 10 & 11
Registration Number 2-78194/811-3500

EXHIBIT INDEX

10.  Consent of Independent Auditors

11.  Financial Statement Schedules and Report of Independent
     Auditors

14.  Financial Data Schedules:
       IDS Life of New York Accounts 4, 5, 6, 9, 10 & 11
       IDS Life Company of New York

<PAGE>
PAGE 1

                   CONSENT OF INDEPENDENT AUDITORS

We consent to the use of our reports dated February 3, 1995 on the
financial statements and financial statement schedules of IDS Life
Insurance Company of New York and our report dated March 17, 1995
on the financial statements of IDS Life Accounts 4, 10, 11, 5, 6
and 9 in Post-Effective Amendment No. 22 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 for the
registration of the Variable Retirement and Combination Retirement
Annuities to be offered by IDS Life Insurance Company of New York.



Minneapolis, Minnesota
April 26, 1995

<PAGE>
PAGE 1 
<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, 1994

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:
  Held to maturity:
    United States Government and
     government agencies and
     authorities (a)                      $      23,491   $      21,150   $      23,491
    States, municipalities and
      political subdivisions                          -               -               -
    All other corporate bonds                   662,992         631,930         662,992

          Total held to maturity                686,483   $     653,080         686,483

  Available for sale:
    United States Government and
     government agencies and
     authorities (a)                      $     145,711   $     135,141   $     135,141
    States, municipalities and
      political subdivisions                        104             105             105
    All other corporate bonds                   328,784         319,857         319,857

          Total available for sale              474,599   $     455,103         455,103

Mortgage loans on real estate                   164,916     XXXXXXXXXX          164,916
Policy loans                                     14,899     XXXXXXXXXX           14,899
Other investments                                 1,524                           1,524

          Total investments               $   1,342,421     XXXXXXXXXX    $   1,322,925



(a) - Includes mortgage-backed securities with a cost and market value of $23,093 and $20,768,
      respectively.

(b) - Includes mortgage-backed securities with a cost and market value of $135,711 and $125,276,
      respectively.

</TABLE>
<PAGE>
PAGE 2 
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE III - SUPPLEMENTARY INSURANCE INFORMATION ($ thousands)
FOR THE YEAR ENDED DECEMBER 31, 1994

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        $   61,442    $1,087,367    $    -       $  1,348        $   - 

Life, DI and
Long-term Care
Insurance            38,636       168,417         -          1,869         7,846

Total            $  100,078    $1,255,784    $    -       $  3,217        $7,846

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

Annuities        $   92,583    $       81    $  9,392     $   4,765          N/A

Life, DI and
Long-term Care
Insurance            15,560        10,214       3,602         3,594          N/A

Total            $  108,143    $   10,295    $ 12,994     $   8,359          N/A

/TABLE
<PAGE>
PAGE 3 
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE III - 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    $1,059,005    $    -       $  1,707        $   - 

Life, DI and
Long-term Care
Insurance            34,591       160,962         -            640         7,110

Total            $   87,891    $1,219,967    $    -       $  2,347        $7,110

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

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 4 
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE III - 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

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

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 IV - REINSURANCE ($ thousands)
FOR THE YEARS ENDED DECEMBER 31, 1994, 1993 AND 1992

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, 1994

Life insurance
  in force                $     3,602,888  $       162,956  $       447,317  $     3,887,249     11.51%

Premiums:
  Life insurance
   & annuities            $         2,219  $           209  $           --   $         2,010      0.00%
  DI &
   long-term care
   insurance                        5,919               83              --             5,836      0.00%
Total premiums            $         8,138  $           292  $             0  $         7,846      0.00%


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%

</TABLE>
<PAGE>
PAGE 6 
<TABLE>
<CAPTION>

IDS LIFE INSURANCE COMPANY OF NEW YORK
SCHEDULE V - VALUATION AND QUALIFYING ACCOUNTS ($ thousands)
FOR THE YEARS ENDED DECEMBER 31, 1994, 1993 AND 1992

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, 1994
- ------------------------------
Reserve for
 Mortgage Loans     $445             $0                 $0              $0              $445
Reserve for
 Fixed Maturities   $1,652           $(1,652)           $0              $0              $0

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

</TABLE>
<PAGE>
PAGE 7







                  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 (a wholly owned subsidiary of IDS Life
Insurance Company) as of December 31, 1994 and 1993, and for each
of the three years in the period ended December 31, 1994, and have
issued our report thereon dated February 3, 1995 (included
elsewhere in this Registration Statement).

Our audits also included the financial statements schedules I, III,
IV and V 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.




Minneapolis, Minnesota
February 3, 1995


<TABLE> <S> <C>
<PAGE>
<ARTICLE>                            6            
<CIK>                       0000703704
<NAME> IDS Life of New York Accounts 4, 10, 11, 5, 6 and 9 
<CURRENCY>                 U.S. DOLLAR
<FISCAL-YEAR-END>          DEC-31-1994            
<PERIOD-START>             JAN-01-1994            
<PERIOD-END>               DEC-31-1994            
<PERIOD-TYPE>                     YEAR
<EXCHANGE-RATE>                      1
<INVESTMENTS-AT-COST>        465079030     
<INVESTMENTS-AT-VALUE>       457338382
<RECEIVABLES>                   945941
<ASSETS-OTHER>                       0            
<OTHER-ITEMS-ASSETS>                 0
<TOTAL-ASSETS>               458284323
<PAYABLE-FOR-SECURITIES>             0
<SENIOR-LONG-TERM-DEBT>              0
<OTHER-ITEMS-LIABILITIES>     (880807)
<TOTAL-LIABILITIES>           (880807)
<SENIOR-EQUITY>                      0
<PAID-IN-CAPITAL-COMMON>             0
<SHARES-COMMON-STOCK>        227639564             
<SHARES-COMMON-PRIOR>        149303625
<ACCUMULATED-NII-CURRENT>            0
<OVERDISTRIBUTION-NII>               0
<ACCUMULATED-NET-GAINS>              0
<OVERDISTRIBUTION-GAINS>             0
<ACCUM-APPREC-OR-DEPREC>             0          
<NET-ASSETS>                 457403516
<DIVIDEND-INCOME>             30319121
<INTEREST-INCOME>                    0
<OTHER-INCOME>                       0
<EXPENSES-NET>               (4081505)
<NET-INVESTMENT-INCOME>       26237616
<REALIZED-GAINS-CURRENT>       (84699)
<APPREC-INCREASE-CURRENT>   (40391393)
<NET-CHANGE-FROM-OPS>       (14238476)
<EQUALIZATION>                       0
<DISTRIBUTIONS-OF-INCOME>            0
<DISTRIBUTIONS-OF-GAINS>             0
<DISTRIBUTIONS-OTHER>                0
<NUMBER-OF-SHARES-SOLD>       91403561
<NUMBER-OF-SHARES-REDEEMED> (13067622)
<SHARES-REINVESTED>                  0
<NET-CHANGE-IN-ASSETS>       112076861
<ACCUMULATED-NII-PRIOR>              0
<ACCUMULATED-GAINS-PRIOR>            0
<OVERDISTRIB-NII-PRIOR>              0
<OVERDIST-NET-GAINS-PRIOR>           0
<GROSS-ADVISORY-FEES>                0 
<INTEREST-EXPENSE>                   0
<GROSS-EXPENSE>              (4081505)
<AVERAGE-NET-ASSETS>         401365085
<PER-SHARE-NAV-BEGIN>                0
<PER-SHARE-NII>                      0
<PER-SHARE-GAIN-APPREC>              0
<PER-SHARE-DIVIDEND>                 0
<PER-SHARE-DISTRIBUTIONS>            0
<RETURNS-OF-CAPITAL>                 0
<PER-SHARE-NAV-END>                  0            
<EXPENSE-RATIO>                      0
<AVG-DEBT-OUTSTANDING>               0
<AVG-DEBT-PER-SHARE>                 0

</TABLE>

<TABLE> <S> <C>
<PAGE>
<ARTICLE>                                        7
<CIK>                                   0000703704    
<NAME>  IDS Life Insurance Company of New York
<MULTIPLIER>                                  1000
<CURRENCY>                             U.S. DOLLAR
<FISCAL-YEAR-END>        DEC-31-1993   DEC-31-1994
<PERIOD-START>           JAN-01-1993   JAN-01-1994
<PERIOD-END>             DEC-31-1993   DEC-31-1994
<PERIOD-TYPE>                   YEAR          YEAR 
<EXCHANGE-RATE>                    1             1
<DEBT-HELD-FOR-SALE>               0        455103
<DEBT-CARRYING-VALUE>        1171023        686483
<DEBT-MARKET-VALUE>          1240593        653080
<EQUITIES>                       190           135
<MORTGAGE>                    123337        164916
<REAL-ESTATE>                      0             0
<TOTAL-INVEST>               1309551       1322925
<CASH>                            0           5262
<RECOVER-REINSURE>               246             3
<DEFERRED-ACQUISITION>         87891        100078
<TOTAL-ASSETS>               1801850       1957574
<POLICY-LOSSES>              1219967       1255784
<UNEARNED-PREMIUMS>                0             0
<POLICY-OTHER>                     0             0
<POLICY-HOLDER-FUNDS>          2347           3217
<NOTES-PAYABLE>                    0             0
<COMMON>                        2000          2000
              0             0
                        0             0
<OTHER-SE>                    158459        169721
<TOTAL-LIABILITY-AND-EQUITY> 1801850       1957574
                      7110          7846
<INVESTMENT-INCOME>          110147         108143
<INVESTMENT-GAINS>              1334           957
<OTHER-INCOME>                 12538         16170
<BENEFITS>                     75824         75313
<UNDERWRITING-AMORTIZATION>    10434         12994
<UNDERWRITING-OTHER>            7652          8359
<INCOME-PRETAX>                37219         36449
<INCOME-TAX>                   13335         12794
<INCOME-CONTINUING>            23884         23655
<DISCONTINUED>                     0             0
<EXTRAORDINARY>                    0             0
<CHANGES>                          0             0      
<NET-INCOME>                   23884         23655
<EPS-PRIMARY>                      0             0
<EPS-DILUTED>                      0             0
<RESERVE-OPEN>                  1026           450
<PROVISION-CURRENT>             8180          9789
<PROVISION-PRIOR>                  0             0
<PAYMENTS-CURRENT>              8756          8537
<PAYMENTS-PRIOR>                   0             0
<RESERVE-CLOSE>                  450          1702
<CUMULATIVE-DEFICIENCY>            0             0

</TABLE>


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