Halliburton Co. v. Commissioner
United States Tax Court
In April 1987, H requested that R make a determination of whether a pension plan sponsored by H sustained a partial termination in 1986. R issued a proposed determination in September 1988 concluding that a partial termination had occurred.
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In April 1987, H requested that R make a determination of whether a pension plan sponsored by H sustained a partial termination in 1986. R issued a proposed determination in September 1988 concluding that a partial termination had occurred. H timely requested an appeals conference, which was held in July 1989. A second appeals conference was held in February 1990. In August 1990, H requested that R exercise his discretion under sec. 7805(b), I.R.C., to limit the retroactive effect of R's final determination in the event R finally determined that a partial termination of the plan occurred in…
1Opinion of the Court
OPINION
Wells, Judge:
The instant case is before us on respondent's motion to dismiss the petitions for declaratory relief for lack of jurisdiction on grounds that petitioners Halliburton Co. (Halliburton) and Ken Nash (Mr. Nash)1 have failed to exhaust their administrative remedies, as required by section 7476(b)(3).2 Halliburton and Mr. Nash argue that they have complied with all of respondent's requirements regarding administrative review of their requests for determination, thus exhausting such remedies, and that we thus have jurisdiction to hear the merits of their petitions for…
2Cases cited21 opinions
- University of Texas v. CamenischSupreme Court of the United States · 1981
- Helvering v. HammelSupreme Court of the United States · 1941
- Walter Camenisch v. The University of TexasCourt of Appeals for the Fifth Circuit · 1980
- B.H.W. Anesthesia Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
- Christian Stewardship Assistance, Inc. v. CommissionerUnited States Tax Court · 1978
16 more not listed; retrieve them via the Exa API.
3Cited by13 opinions
- Romann v. CommissionerUnited States Tax Court · 1998
- Halliburton Co. v. CommissionerUnited States Tax Court · 1993
- Simmons v. CommissionerUnited States Tax Court · 1995
- Alessandra v. CommissionerUnited States Tax Court · 1995
- Dillon v. CommissionerUnited States Tax Court · 1993
8 more not listed; retrieve them via the Exa API.