Halliburton Co. v. Commissioner
United States Tax Court
In the instant declaratory judgment action under sec. 7476, I.R.C., H seeks review of R's proposed determination that a profit sharing plan sponsored by H experienced a partial termination during 1986. A sharp decline in H's business during such year caused H to initiate net layoffs of 3,891 participants in the plan, reducing participation in the plan by 19.85 percent.
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In the instant declaratory judgment action under sec. 7476, I.R.C., H seeks review of R's proposed determination that a profit sharing plan sponsored by H experienced a partial termination during 1986. A sharp decline in H's business during such year caused H to initiate net layoffs of 3,891 participants in the plan, reducing participation in the plan by 19.85 percent. Held: Such discharges did not cause a partial termination of the plan under sec. 411(d)(3), I.R.C., when the discharges are considered in light of all facts and circumstances.
1Opinion of the Court
HALLIBURTON COMPANY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; HALLIBURTON COMPANY, by KEN NASH, EMPLOYEE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Halliburton Co. v. Commissioner
Docket Nos. 26290-90R, 2397-91R
United States Tax Court
100 T.C. 216; 1993 U.S. Tax Ct. LEXIS 14; 100 T.C. No. 15; 16 Employee Benefits Cas. (BNA) 1929;
March 24, 1993, Filed
In the instant declaratory judgment action under sec. 7476, I.R.C., H seeks review of R's proposed determination that a profit sharing plan sponsored by H experienced a partial termination during 1986. A sharp…
2Cases cited34 opinions
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- Higgins v. CommissionerSupreme Court of the United States · 1941
- Martha D. YOUNG, Plaintiff-Appellant, v. SOUTHWESTERN SAVINGS AND LOAN ASSOCIATION, Defendant-AppelleeCourt of Appeals for the Fifth Circuit · 1975
- Helvering v. New York Trust Co.Supreme Court of the United States · 1934
- Robert R. Henn v. National Geographic SocietyCourt of Appeals for the Seventh Circuit · 1987
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