Wells Fargo & Company (f.k.a. Norwest Corporation) and Subsidiaries - Page 2




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               postretirement medical trust in 1991 and, on Ps’                       
               consolidated return for 1991, claimed a deduction for the              
               contribution as an addition to a “qualified asset                      
               account” pursuant to sec. 419A(b), I.R.C.                              
                    R determined that Ps’ method for computing the 1991               
               contribution for postretirement benefits for retirees was              
               improper and resulted in a contribution that exceeded the              
               account limit for a reserve under sec. 419A(c)(2), I.R.C.              
               R further determined deficiencies for years 1992-94 as a               
               result of the determined overfunding in 1991.                          
                    Held, with respect to an employee who is retired                  
               when the reserve is created, the present value of that                 
               employee’s projected benefit may be allocated to the year              
               the reserve is created.  Accordingly, Ps’ contributions                
               to the postretirement medical trust for 1991 did not                   
               cause the qualified asset account to exceed the account                
               limit under sec. 419A(b), I.R.C., with respect to the                  
               reserve for postretirement medical benefits provided in                
               sec. 419A(c)(2), I.R.C.                                                


               Walter A. Pickhardt, Mark A. Hager, and Andrew T. Gardner,             
          for petitioners.                                                            
               Alan M. Jacobson, Randall P. Andreozzi, Christa A. Gruber,             
          and James S. Stanis, for respondent.                                        


                                      Contents                                        
          FINDINGS OF FACT ....................... 4                                  
          A. Background ........................ 5                                    
          B. Norwest’s Welfare Benefit Plans ............. 6                          
          C.   Financial Accounting Standards Board Statement of                      
               Financial Accounting Standards No. 106 .......... 8                    
          D.   Norwest’s Contributions to the Postretirement Medical                  
               Trust ......................... 11                                     
               1.   Funding the Postretirement Medical Trust for 1991 . 11            





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