Memorandum Opinion
WELLS, Judge:
The instant case is before us on a petition for declaratory judgment under section 7476. All section references are to the Internal Revenue Code and all rule references are to the Tax Court Rules of Practice and Procedure. The issue to be decided is whether a profit sharing plan (plan) sponsored by Halliburton Company (Halliburton) experienced a partial termination under section 411(d)(3) for the plan year ending on December...
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