In making a determination if a partial termination has occured can you ignore plan participants who have not worked over one year or have attained age 21? The Plan's eligibility provision is more liberal than this.

No, all plan paricipants are counted and measured as to whether or not a partial termination has occured. Good luck on dealing with this gray area. I use the rough rule of thumb that - if the thought occurrs (partial termination), then I'm probably facing a partial term. BNA portfolios have an excellent desciption of this frustratng area.