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Accordingly, an auditor must determine some evidentially supportable limiting factor, such as space or production capacity, that can help to estimate both a probable maximum revenue that might possibly be derived from the arrangement and the understatement thereof.
equally fact as chair of well as "To say that I am proud of them would be an understatement.
In addition to the existing exceptions regarding change of law and reliance on Chief Counsel ruling, the penalty will not be imposed if an understatement is attributable to either of these new exceptions:
The Chief Counsel of the Internal Revenue Service (IRS) recently issued Chief Counsel Advice Memorandum (CCA) 201519029 to provide additional insight on when it's appropriate to apply the understatement penalty in the presence of willful or reckless conduct.
Judge Niclas Parry told him: "To call you a nuisance is probably an understatement.
6015(b) can also extend to what might be called semi-innocent individuals (those who have some knowledge of an understatement as long as they did not know and had no reason to know the full extent of the understatement).
The article added its own understatement, noting that the structure "is creating about as much interest and hopeful speculation in chemistry and biology as anything that has happened in many months" (12/19/53, p.
As we reported in 2008, understatement can also occur when state survey teams cite some serious deficiencies at too low a level, and we found that the extent of such understatement in fiscal year 2008 was consistent with prior fiscal years.
medieval would be an understatement," said the archdruid of Glastonbury, Dreow Bennett.
This turns out to be a considerable understatement.
To say that Dan is not looking forward to an entire day of hog jokes at his expense would be an understatement.
He was featured awhile back as one of the "Worst Dudes Ever," and I'm here to let you know that Worst Dude Ever is an understatement for this kook.