Substantial Authority definition

Substantial Authority means the weight of authorities for the tax treatment of an item is substantial in relation to the weight of authorities supporting contrary positions.

Substantial Authority has the meaning set forth in Section 3.4(c) of this Agreement.

Substantial Authority means substantial authority within the meaning of Section 6662(d)(2)(B)(i) of the Code and the Treasury Regulations promulgated thereunder.

Examples of Substantial Authority in a sentence

• Substantial authority suggests the probability that the taxpayer’s position is sustained upon audit or litigation is in the 35 to 40 percent range or above.

• Substantial authority is generally viewed by tax professionals as requiring at least a 50% probability that the tax position taken will be sustained on its merits.

• Asked why Valley Medical Center was not included, Ms. Cabe responded that, like Harborview Medical Center, the structures of a district or county hospital require that it report separately.

• Substantial authority brings with it the ability and need to conduct serious, thoughtful analyses of the issues it faces.

• Substantial authority suggests that the probability that the taxpayer’s position is sustained upon audit or litigation is in the 35 to 40 percent range or above.

More Definitions of Substantial Authority

Substantial Authority as defined in Section 2.1.

Substantial Authority has the meaning provided in the Treasury Regulations under section 6662 of the Code.

Substantial Authority means, in addition to any definition of substantial authority incorporated by subsection (j), that the following authority supports the tax treatment of an item:

Substantial Authority shall have the meaning assigned to such term in Section 6662(d)(2)(B) of the Code and Treas. Reg. § 1.6662-4(d) or any successor provisions that set forth the standard to avoid the incurrence of accuracy-related penalties under the Code;

Substantial Authority. For Federal income tax purposes, has the meaning applicable for purposes of Section 6662 of the Code and relevant Treasury regulations.

Substantial Authority means “substantial authority” within the meaning of Section 6662(d)(2)(B) of the Code and Treasury Regulations Section 1.6662-4(d) (or, in the case of any Taxes not subject to Section 6662(a), an analogous standard).

Substantial Authority shall have the meaning set forth in Section 3.3(a).