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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