Legal Opinion

Wells Fargo & Company (f.k.a. Norwest Corporation) and Subsidiaries v. Commissioner

United States Tax Court

Decided February 13, 2003No. 7620-98, 12136-98, 19891-98, 7282-99, 12484-99Unknown

1Opinion of the Court

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…

2Cases cited33 opinions

  1. Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
  2. Morissette v. United StatesSupreme Court of the United States · 1952
  3. Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
  4. Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
  5. United States v. American Trucking AssociationsSupreme Court of the United States · 1940

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