Central States switch from Partial Withdrawal to Complete Withdrawal

Employer has partial withdrawal from Central States followed 2 years later by a complete withdrawal.

In calculating liability under the partial withdrawal, Administrator included 2007 & 2008 in calculation. On Complete withdrawal 2 years later, actuary is still including 2007 & 2008 contribution & UVB in calculation. Shouldn't the "first 2 years" drop off when calculating the "Complete Withdrawal" ?

thanks for any insight or citations

I recall on a complete withdrawal that the actuary calculates the years of the partial withdrawal as well and then provides a credit for any prior partial withdrawal liability payments.  I had a similar issue a number of years ago and I believe that is how it was done.