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February 28, 1995
Securities and Exchange Commission
Attention: Filing Desk, Stop 1-4
450 Fifth Street, N.W.
Washington, D.C. 20549-1004
RE: Rule 24f-2 Notice for
IDS Life of New York Account SBS
File No. 33-45776
Commissioners:
[i] In accordance with the provisions of Rule 24f-2,
IDS Life of New York Account SBS hereby files its Rule 24f-2
Notice for the fiscal year ended December 31, 1994 ("Fiscal
Year").
[ii] Amount of securities registered other
than under 24f-2 which were unsold at
the beginning of the fiscal year $ 0
[iii] Amount of securities registered during
the fiscal year other than under 24f-2** $ 0
[iv] Amount of securities sold during the
fiscal year $6,061,000*
[v] Amount of securities sold pursuant to 24f-2 $6,061,000
[vi] Fee $6,061,000 X 0.00034483 equals $2,090.01
* Sales of $8,103,000 minus redemptions of $2,042,000
Enclosed please find an opinion of counsel.
If there are any questions, please contact the undersigned.
Very truly yours,
Mary Ellyn Minenko
Counsel
(612) 671-3678
MEM/JDS/cah
Enclosures
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EXHIBIT INDEX
(b) (10) OPINION OF COUNSEL
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February 28, 1995
IDS Life Insurance Company of New York
20 Madison Avenue Extension
Albany, New York 12203
Gentlemen:
Reference is made to the Registration Statement on Form N-4 (File
No. 33-40779) under the Securities Act of 1933 which became
effective October 16, 1991, registering an indefinite amount of
securities pursuant to Rule 24f-2 adopted under the Investment
Company Act of 1940. In connection with the Rule 24f-2
Notification for the fiscal year ended December 31, 1994, I have
made such examination of matter of fact and law as I have deemed
appropriate, and am of the opinion that:
1) IDS Life of New York Account SBS, is a validly organized and
existing separate account of IDS Life Insurance Company duly
authorized, as a unit of investment trust, with the power and
authority to issue and sell the securities registered, and
2) The securities issued, being variable annuity contracts, were
legally issued, non-assessable and require no further payment
by the purchaser.
I hereby consent that the foregoing opinion may be used in
connection with the Rule 24f-2 Notification.
Sincerely,
Mary Ellyn Minenko
Attorney at Law
Minneapolis, MN 55440-0010
MEM/JDS/cah
