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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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