Wells Fargo & Co. v. Comm'r
United States Tax Court
12484-9 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.
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12484-9 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…
1Opinion of the Court
WELLS FARGO & COMPANY (F.K.A. NORWEST CORPORATION) AND SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wells Fargo & Co. v. Comm'r
No. 7620-98; No. 12136-98; No. 19891-98; No. 7282-99; No. 12484-991
United States Tax Court
120 T.C. 69; 2003 U.S. Tax Ct. LEXIS 6; 120 T.C. No. 5;
February 13, 2003, Filed
In computing petitioners' consolidated income tax for 1991-94, petitioners were 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.
12484-9 For the years 1991-94,…
2Cases cited32 opinions
- Landgraf v. USI Film ProductsSupreme Court of the United States · 1994
- Morissette v. United StatesSupreme Court of the United States · 1952
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
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