Wells Fargo & Company (f.k.a. Norwest Corporation) and Subsidiaries - Page 1
















                                   120 T.C. No. 5                                     


                               UNITED STATES TAX COURT                                


               WELLS FARGO & COMPANY (f.k.a. NORWEST CORPORATION) AND                 
                            SUBSIDIARIES, Petitioners v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos.  7620-98, 12136-98,    Filed February 13, 2003.            
                           19891-98,  7282-99,                                        
                           12484-99.1                                                 


                    For the years 1991-94, Ps made contributions to a                 
               voluntary employee benefit trust (the postretirement                   
               medical trust) for the purpose of providing                            
               postretirement medical benefits to their employees.  For               
               1991, Ps’ actuary computed the present value of future                 
               postretirement medical benefits for active employees to                
               be $14,096,473 and for retired employees to be                         
               $27,759,057. The actuary divided the $14,096,473 for                   
               active employees by the average actuarial present value                
               of future service to produce a 1991 funding amount of                  
               $2,930,660 for active employees.  The actuary determined               
               that the $27,759,057 for retired employees could be fully              
               funded in 1991.  Ps contributed $30,689,717 to the                     


               1    These cases have been consolidated for trial, briefing,           
          and opinion solely with respect to the issue involved herein.               





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