United States Tax Court March 24, 1993, Docket Nos. 26290-90R, 2397-91R (Halliburton Co. v. Commissioner)

lead-opinion

OPINION

Wells, Judge:

The instant case is before us on a petition for declaratory judgment under section 7476. The issue presented for decision is whether a profit sharing plan sponsored by Halliburton Co. (Halliburton) experienced a partial termination under section 411(d)(3) for the plan year ending on December 31, 1986.