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HALLIBURTON CO. v. COMMISSIONER

Docket Nos. 26290-90R, 2397-91R.

100 T.C. 216 (1993)

HALLIBURTON COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT HALLIBURTON COMPANY, BY KEN NASH, EMPLOYEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 24, 1993.

Attorney(s) appearing for the Case

Donald F. Wood, Douglas E. Hamel, and Miriam M. Burke, for petitioner in docket No. 26290-90R.*

Ken Nash, pro se in docket No. 2397-91R.

James W. Lessis, for respondent.**

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.

Unless otherwise indicated, all section references are to the Internal Revenue...

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