Legal Opinion

Halliburton Co. v. Commissioner

United States Tax Court

Decided February 4, 1992No. Docket Nos. 26290-90R, 2397-91RPublished

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

Halliburton Company, Petitioner v. Commissioner of Internal Revenue, Respondent; Halliburton Company, by Ken Nash, Petitioner v. Commissioner of Internal Revenue, Respondent

Halliburton Co. v. Commissioner

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

United States Tax Court

98 T.C. 88; 1992 U.S. Tax Ct. LEXIS 11; 98 T.C. No. 8;

February 4, 1992, Filed

Appropriate orders will be issued.

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…

2Cases cited22 opinions

  1. University of Texas v. CamenischSupreme Court of the United States · 1981
  2. Helvering v. HammelSupreme Court of the United States · 1941
  3. Walter Camenisch v. The University of TexasCourt of Appeals for the Fifth Circuit · 1980
  4. B.H.W. Anesthesia Foundation, Inc. v. CommissionerUnited States Tax Court · 1979
  5. Christian Stewardship Assistance, Inc. v. CommissionerUnited States Tax Court · 1978

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