JACOBS, Judge: Respondent determined deficiencies in Federal income tax and accuracy-related penalties with regard to petitioners' consolidated returns for 1990-94 as follows:

120 T.C. 69">*71

Some of the facts have been stipulated and are found accordingly. The stipulations of facts and the attached exhibits are incorporated herein by this reference.

Norwest Corp. ³ (Norwest) is a multibank holding company organized in 1929. It owns substantially all of the outstanding capital stock of numerous commercial banks in Minnesota, Iowa, South Dakota, Nebraska, Wisconsin, North Dakota, Montana, Wyoming, Illinois, Indiana, and Arizona. 2003 U.S. Tax Ct. LEXIS 6">*9 Norwest also owns subsidiaries engaged in various businesses related to banking, principally mortgage banking, equipment leasing, agricultural finance, commercial finance, consumer finance, securities dealings and underwriting, insurance agency services, computer and data processing services, corporate trust services, and venture capital investments. For each of the years at issue, Norwest and its subsidiaries filed consolidated Federal income tax returns.

120 T.C. 69">*72 On November 2, 1998, Wells Fargo & Co. was merged into a wholly owned subsidiary of Norwest. Simultaneously with the merger, Norwest changed its name to Wells Fargo & Co. Hereinafter, reference to Norwest is to Norwest and its subsidiaries before the merger with Wells Fargo & Co.

When Norwest filed the petitions in docket Nos. 7620-98 and 12136-98 (which was before the merger), its principal place of business was in Minneapolis, Minnesota. At the time Wells Fargo & Co. filed the petitions in docket Nos. 19891-98, 7282-99, and 12484-99 (which was after the merger), its principal place of business was in San Francisco, California.

On January 2003 U.S. Tax Ct. LEXIS 6">*10 1, 1930, Norwest established the Norwest Corp. Medical Plan, also known as the Norwest Corp. Hospital-Medical Plan (the medical plan). The medical plan is a self-insured welfare plan providing for the payment (or reimbursement) of all or a portion of covered medical expenses incurred by Norwest's eligible employees (including eligible retired employees) and their eligible dependents. Since June 1, 1957, the medical plan has provided postretirement medical benefits (i.e., medical benefits for its retirees), pursuant to a rider issued by Prudential Insurance Co. of America, relating to Norwest's group health insurance policy.

Over the years, Norwest established other plans, in addition to the medical plan, to provide benefits for Norwest's eligible employees (including under some plans retired employees) and their eligible dependents. The employee benefit plans include a long- term disability plan, ^{42003 U.S. Tax Ct. LEXIS 6">*11} a dental plan, ⁵ a severance plan, ⁶ an HMO premium plan, ⁷ and a choice plus medical plan. ⁸

120 T.C. 69">*73 On November 11, 1978, Norwest established, effective January 1, 1979, a VEBA trust, under section 501(c)(9), to fund the employee benefit plans then in existence 2003 U.S. Tax Ct. LEXIS 6">*12 (i.e., the medical plan and the long-term disability plan). This trust was originally called the "Northwest Bancorporation Employee Benefit Trust" and is hereinafter referred to as the master trust. Over the years, the master trust was amended to fund the dental plan and the HMO premium plan. The master trust was amended and restated effective January 1, 1991; the name of the master trust was changed to the Norwest Corp. Employee Benefit Trust.

From 1957 to 1991, Norwest paid medical benefits for retired employees as claims were submitted; i.e., on a "pay-as- you-go" basis. For financial accounting and tax purposes, Norwest recognized these costs when the benefits were paid.

In 1990, new financial accounting rules for nonpension, postretirement benefits were promulgated in Statement of Financial Accounting Standards No. 106 (SFAS 106). Pursuant to SFAS 106, for financial accounting purposes, employers must accrue (during the employment of an employee) the cost of future health care benefits to be paid to the employee after retirement. ⁹ Thus, because SFAS 106 applies to a postretirement benefit 2003 U.S. Tax Ct. LEXIS 6">*13 plan regardless of the means or timing of funding, the employer cannot postpone recognition of the cost of the employee's postretirement benefit by contributing at the time of retirement a lump sum equal to the present value of the employee's benefit (terminal funding). SFAS 106, par. 8.

SFAS 106 permits an employer to immediately recognize, at the date of initial application of SFAS 106, obligations that the employer had not accrued for financial purposes in prior years (transition obligation ^{102003 U.S. Tax Ct. LEXIS 6">*14} ). SFAS 106, par. 260. Immediate 120 T.C. 69">*74 recognition is not permitted after the initial application of SFAS 106. ¹¹

Norwest adopted SFAS 106, effective January 1, 1992. As a consequence, Norwest elected to recognize as an immediate expense its unrecognized transition obligation. ^{122003 U.S. Tax Ct. LEXIS 6">*15} The amount of this obligation was $ 71.7 million (after tax).

On December 20, 1991, Norwest established the Norwest Corp. Employee Benefit Trust for Retiree Medical Benefits (the postretirement medical trust), effective December 16, 1991. ¹³ The postretirement medical trust funded postretirement medical benefits to be provided to all employees, both active and retired (other than "key employees"), under Norwest's medical plan. Simultaneously with the creation of the postretirement medical trust, Norwest amended the master trust, effective December 16, 1991, to eliminate the master trust's responsibility to pay postretirement medical benefits for all but key employees.

For the years 1991-94, Norwest made contributions to the postretirement medical trust for the purpose of providing postretirement 2003 U.S. Tax Ct. LEXIS 6">*16 medical benefits.

During the years at issue, William M. Mercer, Inc. (hereinafter referred to as Mercer), a national actuarial firm, prepared actuarial funding valuations for Norwest's pension plans and postretirement medical plans. Sometime in late 120 T.C. 69">*75 1990/early 1991, Norwest expressed to Mercer an interest in funding its retiree medical benefits plan. Norwest understood that employers were permitted a tax deduction for funding a reserve for postretirement medical benefits.

On April 14, 1992, Mercer prepared and presented to Norwest a valuation report entitled "Norwest Corporation Actuarial Funding Valuation of the Post-retirement Medical Plans as of January 1, 1991" (the 1991 valuation). Mercer computed the present value of future medical benefits to be $ 14,096,473 for active employees and $ 27,759,057 for retired employees. In determining these computations, Mercer used a pretax investment rate assumption of 9 percent and an after-tax investment rate of 5.5 percent. Mercer divided the $ 14,096,473 for active employees by the "average actuarial present value of future service" for the active employees (4.81) to produce a 1991 funding 2003 U.S. Tax Ct. LEXIS 6">*17 amount of $ 2,930,660 for active employees. Mercer determined that, because the retired employees had no remaining working life, the present value of future benefits for retired employees ($ 27,759,057) could be funded in 1991. Mercer believed that Norwest's resulting reserve for active and retired employees ($ 30,689,717) would be within the section 419A(c)(2) account limit.

On the basis of the 1991 valuation report, Norwest contributed $ 30,689,717 to the postretirement medical trust in 1991. On the consolidated return for 1991, Norwest claimed a deduction for the contribution as an addition to a "qualified asset account" pursuant to section 419A(b).

At the request of Norwest, Mercer prepared actuarial funding valuation reports as of January 1 for each year 1992-94, relating to the funding of the postretirement medical trust (the 1992-94 valuation reports). In the 1992-94 valuation reports, Mercer computed the end-of-year contributions to be $ 6,859,600, $ 11,308,043, and $ 12,247,933, respectively. Mercer calculated the contribution amount to be equal to a fraction. The numerator of the fraction was the present value of future 2003 U.S. Tax Ct. LEXIS 6">*18 benefits for active employees and retirees, reduced by the sum of the value of (a) the postretirement medical trust assets and (b) the section 401(h) account assets. The denominator 120 T.C. 69">*76 of the fraction was the average present value of future working lifetimes of the employees. The present value of the future working life of an employee is comparable to the present value of an annuity (computed with the actuarial interest rate used by the plan) that pays $ 1 each year until the employee is expected to retire.

In order to compute the present value of future benefits in the 1991-94 valuation reports, Mercer made certain actuarial assumptions, including investment rates, the number of employees who would "retire, die, terminate their services or become disabled, their ages at termination, and their expected benefits." Mercer requested Norwest to provide an estimate of Norwest's effective tax rates for years 1991-94. Norwest advised Mercer that those tax rates would be approximately 39 percent in 1991-92 and 40 percent in 1993- 94.

The pretax and after-tax investment rates Mercer used in the 1991-94 2003 U.S. Tax Ct. LEXIS 6">*19 valuation reports were as follows:

The following chart illustrates the various factors disclosed in the 1991-94 valuation reports (minor computational discrepancies are unexplained):

In 1991-94, Norwest made contributions to the postretirement medical trust of $ 30,689,717, $ 2,170,000, $ 13,791,600, and $ 12,247,933, respectively. During 1992-94, Norwest's retired employees made contributions to the postretirement medical trust of $ 473,832.62, $ 736,176.25, and $ 784,906.22, respectively. In 1993, $ 175,216 was transferred from the master trust to the postretirement medical trust.

Respondent determined that Norwest's 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 section 419A(c)(2). As a result of the 1991 overfunding, respondent determined that the reserve was also overfunded in 1992-94.

Sections 419 and 419A limit deductions for contributions made by a taxpayer to an employee welfare benefit fund. ¹⁴ In general, 2003 U.S. Tax Ct. LEXIS 6">*21 section 419(a)(1) denies a deduction for contributions paid or accrued by an employer to a welfare benefit fund. However, if the contributions would otherwise be deductible, then section 419(a)(2) permits a deduction for the taxable year in which the contribution is paid, subject to the limitation contained in section 419(b).

Section 419(b) limits the deduction for any taxable year to the welfare benefit fund's "qualified cost". ¹⁵ The fund's qualified cost is equal to the sum of the fund's "qualified direct 120 T.C. 69">*78 cost" for the year, and, subject to the limitation of section 419A(b), any addition to a "qualified asset account" for the year. ¹⁶Sec. 419(c)(1).

Section 419A(a) defines a qualified asset account as any account consisting of assets set aside to provide 2003 U.S. Tax Ct. LEXIS 6">*22 for the payment of (1) disability benefits, (2) medical benefits, (3) SUB (supplemental compensation benefit) or severance pay benefits, or (4) life insurance benefits. Additions to a qualified asset account are included in the fund's qualified cost only to the extent they do not exceed the fund's "account limit" for the taxable year. Sec. 419A(b).

For purposes of the present case, the account limit includes: (1) The amount reasonably and actuarially necessary to fund claims that are incurred but unpaid as of the close of the taxable year and related administrative costs and (2) the amount of an additional reserve funded over the working lives of the covered employees and actuarially determined on a level basis (using assumptions that are reasonable in the aggregate) as necessary for postretirement medical and life insurance benefits. Sec. 419A(c)(1) and (2).

At issue in this case is the computation of the account limit for the reserve necessary for postretirement medical benefits provided under section 419A(c)(2). Petitioners and respondent disagree as to the proper method for computing the account limit for "a reserve funded over the working lives of the covered employees and actuarially 2003 U.S. Tax Ct. LEXIS 6">*23 determined on a level basis (using assumptions that are reasonable in the aggregate) as necessary for post-retirement medical benefits". Additionally, respondent asserts that the investment rates petitioners used in computing the reserve were too low.

For 1991, Mercer computed Norwest's contribution to the postretirement medical trust by including (1) the present value of postretirement medical benefits for the active employees amortized over the employees' remaining working lives, and (2) the entire present value of the postretirement medical benefits for the retirees funded in 1 year (the Mercer method). 120 T.C. 69">*79 Respondent asserts that Mercer's methodology in computing Norwest's 1991 contribution for medical benefits to retirees was improper and resulted in a contribution that exceeded the account limit for a reserve under section 419A(c)(2). ^{172003 U.S. Tax Ct. LEXIS 6">*24} For the reasons set forth below, we disagree with respondent's assertion. To the contrary, we approve of the Mercer method used in computing Norwest's 1991 contribution to the postretirement trust.

The parties rely on expert reports and testimony to explain actuarial methods appropriate for computing a reserve for postretirement medical benefits described in section 419A(c)(2) and to compute the account limit using those methods. Petitioners presented the reports and testimony of two expert witnesses: Messrs. Ira Cohen and Gary Scharmer. Respondent presented the expert report and testimony of Mr. Richard Daskais. The experts generally agree that actuarial cost methods approved for computing the funding of defined benefit pension plans may be used for computing the funding of postretirement medical benefits.

In calculating reserves, actuaries first calculate the stream of benefits to be paid from the trust (the year-by-year benefit payments to be made to covered employees in future years) and then calculate the present value of that stream by discounting the payment each year at a determined interest or investment rate. The stream of benefit payments is based on actuarial assumptions. For postretirement medical benefits, these assumptions include those as to when employees will retire, how long they will live after retirement, how 2003 U.S. Tax Ct. LEXIS 6">*25 many will have spouses entitled to benefits, the annual cost of the benefits for each retired employee or spouse, and an interest rate for discounting the stream of benefits to present value.

An actuary uses an actuarial cost method to assign the present value of promised benefits to individual plan years as an annual cost. The portion of the total cost of the plan that is assigned by the actuarial cost method to the current year or to a future year is called the normal cost.

120 T.C. 69">*80 In general, six actuarial cost methods (or variations thereof) are used for purposes of computing pension costs. They include (1) the unit credit method (also known as the accrued benefit cost method); (2) the entry age normal cost method; (3) the individual level premium cost method; (4) the aggregate cost method; (5) the attained age normal cost method; and (6) the frozen initial liability cost method. The methods discussed by the parties' experts are the aggregate cost method (respondent's preferred method), the entry age normal cost method (petitioners' preferred method), and the individual level premium cost method (the method Mercer used in 1991 and the one which we find satisfies the requirements of section 419A(c)(2)).

The aggregate cost method calculates costs for all employees on an aggregate basis. The aggregate cost method computes normal costs in relation to the assets of the fund; this method does not calculate an accrued liability independent of those assets.

In computing the normal cost under the aggregate cost method, the value of the plan assets is subtracted from the present value of future benefits for all participants. The remaining present value of future benefits is then divided by the sum of the present value of the future working lives of the active employees. The present value of the future working life of an employee is comparable to the present value of an annuity (computed with the actuarial interest rate used by the plan) that pays $ 1 each year until the employee is expected to retire.

The entry age normal cost method can be applied on an individual or aggregate basis; in this case, it is applied on an individual basis. Under the entry age normal cost method, the actuarial present value of each employee's projected benefit is spread over the entire length of the employee's service, beginning at the date the employee began service 2003 U.S. Tax Ct. LEXIS 6">*27 with the employer and ending with the anticipated normal retirement date.

120 T.C. 69">*81 The normal cost computed under the entry age normal cost method is a dollar amount which, if paid annually and allowed to accumulate from the date the employee began service until the projected retirement date of that employee, will have accumulated at retirement the amount necessary to fully fund the benefit to the covered employee. The actuarial accrued liability is the portion of the actuarial present value that is not provided for by future normal costs.

The individual level premium cost method is an individual method, similar to the entry age normal cost method. Under the individual level premium cost method, the normal cost is separately determined for each covered employee as a level dollar amount which, if accumulated from the later of the date the plan is established or the date that the employee was hired, would accumulate at retirement the amount necessary to fully fund the benefit to the covered employee.

The primary difference between the individual level premium cost method and the entry age normal cost method is the date when normal cost is assumed to commence. 2003 U.S. Tax Ct. LEXIS 6">*28 If the plan is established after the employee is hired, under the entry age normal cost method, normal cost is assumed to have retroactively commenced at the date of hire. Under the individual level premium cost method, normal cost begins no earlier than the date the plan is established.

The parties' experts described the ways that actuaries interpret the account limit for a reserve provided in section 419A(c)(2) and made computations using variations of the aggregate and entry age normal cost methods.

Mr. Cohen, one of petitioners' experts, is an expert in actuarial science and a principal at PricewaterhouseCoopers LLP, advising clients on various matters involving actuarial, tax, pension, and postretirement medical issues. He is a fellow of the Society of Actuaries, an enrolled actuary under ERISA, and a member of the American Academy of Actuaries. From 1970-86, Mr. Cohen was employed by the Internal 120 T.C. 69">*82 Revenue Service, serving in a variety of positions, including director of the Employee Plans, Technical and Actuarial Division.

Mr. Cohen uses the terms "reserve" and "accrued liability" interchangeably and posits that the reserve for retirees 2003 U.S. Tax Ct. LEXIS 6">*29 is the present value of future benefits. In Mr. Cohen's opinion, the aggregate cost method is not appropriate for computing the account limit for a reserve for postretirement benefits because that method does not directly compute an accrued liability and fails to fully fund the reserve for an employee upon retirement. In his opinion, the entry age normal cost method is the appropriate method because that method allocates the cost over the entire working life of an employee, directly computes an accrued liability, and provides for full funding upon retirement.

Mr. Cohen opined that (1) the account limit for the reserve is equal to the reserve (accrued liability) computed under the entry age normal cost method, (2) for retirees, the reserve (accrued liability) is the present value of future benefits, and (3) for active employees, the reserve is the present value of future benefits minus the present value of future normal costs.

Mr. Scharmer is an expert in actuarial science and is a principal at Mercer. He is a fellow of the Society of Actuaries, an enrolled actuary under ERISA, a member of the American Academy of Actuaries, and a member of the Conference of Actuaries.

Mr. 2003 U.S. Tax Ct. LEXIS 6">*30 Scharmer opined that the account limit for a reserve under section 419A(c)(2) was equal to the accrued liability using the entry age normal cost method. For 1991-94, Mr. Scharmer calculated the account limit for the reserve by applying the entry age normal cost method and by using the same facts and assumptions that Mercer relied upon when it prepared the 1991-94 valuation reports. Mr. Scharmer computed the accrued liability (dollars in millions) on the valuation date for each year as follows:120 T.C. 69">*83

Mr. Daskais, respondent's expert, is an expert in actuarial science. He is a fellow of the Society of Actuaries and was an enrolled actuary under ERISA from 1976 to 1995.

Mr. Daskais opined that "actuarially determined on a level basis" means that the systematic year-to-year increments to the reserve are the same (or "level" in some sense) each year. Examples of level increments that are appropriate for computing a reserve for postretirement medical benefits include (1) a uniform (or level) dollar amount each year or (2) a uniform (or level) dollar amount per active employee each year, so that the total dollar amount increases or 120 T.C. 69">*84 decreases as the number of active employees increases or decreases. ^{182003 U.S. Tax Ct. LEXIS 6">*32}

Mr. Daskais opined that in actuarial parlance a "reserve funded over the working lives of covered employees" is a "one-sentence description of the aggregate cost method." It means a reserve, determined on the basis of an actuarial cost method and actuarial assumptions, that will increase from year to year and will be exactly sufficient to provide the trust fund's benefits at the end of the working lives of the covered employees. Mr. Daskais acknowledged that the reserve funded using the aggregate cost method will not be fully funded with respect to an individual employee upon retirement. In Mr. Daskais's opinion, full funding upon retirement of an individual employee is not required; in his opinion the end of the working lives of covered employees occurs when the employment of all covered employees has terminated.

Mr. Daskais computed the 2003 U.S. Tax Ct. LEXIS 6">*33 maximum contribution for 1991-94 to the postretirement medical trust deductible under section 419 by applying the aggregate cost method using the same actuarial values (including the investment rate) Mercer used, as follows:

In Mr. Daskais's opinion, the investment rates Mercer used were unreasonably low. Mr. Daskais recalculated the contribution limit by applying the aggregate cost method using the Mercer assumptions but substituting investment rates that, in his opinion, were reasonable. Under these computations, he determined that the maximum contributions for 1991-94 were as follows:

Mr. Daskais opined that, if the funding method used to calculate the reserve computes an accrued liability, that liability must be amortized. In Mr. Daskais's opinion, since there are no specific amortization rules applicable to the funding of postretirement medical benefits in section 419A or in the income tax regulations, the amortization rules applicable to pensions should be applied.

120 T.C. 69">*86 Mr. Daskais calculated the contribution limit by applying the entry age normal cost method and by using the same facts and assumptions Mercer used. He amortized the accrued liability over the present value of the remaining working lives of the active employees. Under these computations, he determined that the maximum contributions (dollars in millions; discrepancies attributable to rounding) for 1991-94 were as follows:

120 T.C. 69">*87 Mr. Daskais also calculated the contribution limit by applying his variation of the entry age normal cost method (amortizing the accrued liability over the remaining lives of the active employees) as above but substituting investment rates that, in his opinion, were reasonable. Under these computations, he determined that the maximum contributions (dollars in millions; discrepancies attributable to rounding) for 1991-94 were as follows:

120 T.C. 69">*88 Petitioners assert that the reserve under section 419A(c)(2) refers to the employer's accrued liability to provide the postretirement benefits. Petitioners maintain that, since the entry age normal cost method is the only method that directly computes an accrued liability and allocates the present value of an employee's future benefit over the employee's entire working life, the account limit for the reserve is equal to the accrued liability computed under the entry age normal cost method. Petitioners further maintain that (1) for a retiree the accrued liability is the present value of the employee's future benefits, and (2) for an active employee the accrued liability is the present value of the employee's future benefits minus the present value of future normal costs determined under the entry age normal cost method. Petitioners contend that their contribution to the reserve for each year at issue did not cause the reserve to exceed the account limit and, therefore, the contributions were deductible under section 419.

Respondent 2003 U.S. Tax Ct. LEXIS 6">*38 argues that petitioners' position is inconsistent with (1) the language of section 419A(c)(2), (2) the established judicial precedent interpreting that section, (3) Congress's purpose in enacting that section, (4) the accepted interpretation given "nearly identical language" in the provisions governing plans, (5) the law in effect before the enactment of section 419, and (6) principles of actuarial practice. Respondent contends that the cost of the postretirement benefit must be spread over the remaining working lives of the covered employees. Respondent further contends that, since retirees have no remaining working lives, the cost must spread over the remaining working lives of the active employees. Respondent concludes, therefore, that the aggregate cost method is the proper method for computing the account limit for the reserve under section 419A(c)(2). Respondent asserts in the alternative that, if the entry age normal cost method is a proper method, then the accrued liability must be amortized over the remaining lives of the active employees.

"Our first step in interpreting a statute is to determine whether the language at issue has a plain and unambiguous 2003 U.S. Tax Ct. LEXIS 6">*39 meaning with regard to the particular dispute in the case." Robinson v. Shell Oil Co., 519 U.S. 337, 340, 136 L. Ed. 2d 808">136 L. Ed. 2d 808, 117 S. Ct. 843">117 S. Ct. 843 (1997). We look to the legislative history primarily to learn the purpose of the statute and to resolve any ambiguity in the words contained in the text. Landgraf v. USI Film Prods., 511 U.S. 244, 128 L. Ed. 2d 229">128 L. Ed. 2d 229, 114 S. Ct. 1483">114 S. Ct. 1483 (1994); Commissioner v. Soliman, 506 U.S. 168, 174, 121 L. Ed. 2d 634">121 L. Ed. 2d 634, 113 S. Ct. 701">113 S. Ct. 701 (1993); Consumer Product Safety Comm'n v. GTE Sylvania, Inc., 447 U.S. 102">447 U.S. 102, 447 U.S. 102">108, 64 L. Ed. 2d 766">64 L. Ed. 2d 766, 100 S. Ct. 2051">100 S. Ct. 2051 (1980); United States v. Am. Trucking Associations, Inc., 310 U.S. 534, 543-544, 84 L. Ed. 1345">84 L. Ed. 1345, 60 S. Ct. 1059">60 S. Ct. 1059 (1940); Allen v. Commissioner, 118 T.C. 1">118 T.C. 1, 118 T.C. 1">7 (2002); Venture Funding, Ltd. v. Commissioner, 110 T.C. 236">110 T.C. 236, 110 T.C. 236">241-242 (1998), affd. without published opinion 198 F.3d 248">198 F.3d 248, 1999 U.S. App. LEXIS 29856">1999 U.S. App. LEXIS 29856, 8499-2 U.S. Tax Cas. (CCH) P50972 (6th Cir. 1999); A.F.T.R.2d (RIA) 6929, Trans City Life Ins. Co. v. Commissioner, 106 T.C. 274">106 T.C. 274, 106 T.C. 274">299 (1996). Where Congress has expressed its will in reasonably plain terms, those terms must ordinarily be regarded as conclusive. Negonsott v. Samuels, 507 U.S. 99, 104, 122 L. Ed. 2d 457">122 L. Ed. 2d 457, 113 S. Ct. 1119">113 S. Ct. 1119 (1993).

The 2003 U.S. Tax Ct. LEXIS 6">*40 plainness or ambiguity of statutory language is determined by reference to the language itself, the specific context in which that language is used, and the broader context of the statute as a whole. Estate of Cowart v. Nicklos Drilling Co., 505 U.S. 469, 120 L. Ed. 2d 379">120 L. Ed. 2d 379, 112 S. Ct. 2589">112 S. Ct. 2589 (1992); McCarthy v. Bronson, 500 U.S. 136, 139, 114 L. Ed. 2d 194">114 L. Ed. 2d 194, 111 S. Ct. 1737">111 S. Ct. 1737 (1991). In analyzing the plain meaning of section 419A(c)(2), we examine the section as a whole, with all of its subsections in mind. See Hellmich v. Hellman, 276 U.S. 233, 237, 72 L. Ed. 544">72 L. Ed. 544, 48 S. Ct. 244">48 S. Ct. 244 (1928); Huffman v. Commissioner, 978 F.2d 1139, 1145 (9th Cir. 1992), affg. in part, revg. and remanding in part T.C. Memo. 1991-144.

We begin with the specific language of section 419A(c)(2), which provides: