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IRS: Service While Plan is Frozen Cannot Be Ignored for Vesting Purposes if Formula Later Unfrozen
Internal Revenue Service [IRS] 
[Official Guidance] June 9, 2003
Rev. Rul. 2003-65. Excerpt: The freezing of accruals under a qualified retirement plan, so that a partial termination of the plan occurs, does not constitute a plan termination for purposes of determining whether service for the plan sponsor after the plan was established may be disregarded toward vesting if accruals resume under the plan. [So] all years of service for the plan sponsor following the establishment of the previously frozen plan must be taken into account for purposes of vesting.
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