Wells Fargo & Company (f.k.a. Norwest Corporation) and Subsidiaries - Page 54




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                  In computing Norwest’s contribution for 1991, Mercer applied                          
            a reasonable investment rate and used the appropriate individual                            
            level premium cost method.  We conclude, therefore, that Norwest’s                          
            contribution to fund the reserve under section 419A(c)(2) for 1991                          
            did not exceed the account limit.                                                           
                  Further, for years 1992-94, even using the higher after-tax                           
            investment rates Mr. Daskais proposed of 6.0 percent for 1992, 5.7                          
            percent for 1993, and 4.9 percent for 1994, it is clear that                                
            Norwest’s contributions to fund the reserve do not exceed the                               
            account limit when the reserve is computed by applying the                                  
            individual level premium cost method.                                                       
                  We conclude that Norwest’s contributions to the postretirement                        
            benefit trust to fund a reserve for postretirement medical benefits                         
            for 1991-94 did not exceed the account limit for a reserve under                            
            section 419A(c)(2).  We hold, therefore, that in computing                                  
            petitioners’ consolidated income tax for 1991-94, petitioners are                           
            entitled to deductions for postretirement medical benefit                                   
            contributions of $30,689,717 in 1991, $2,170,000 in 1992,                                   
            $13,791,600 in 1993, and $12,247,933 in 1994.                                               
                  To reflect the foregoing, and because other issues in these                           
            cases remain for resolution,                                                                


                                                            An appropriate order will                  
                                                       be issued.                                       






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