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Attorneys general and district attorneys have substantial authority to determine how prosecutors working under them exercise their enormous discretion.
It exercises substantial powers.
(C)When substantial authority determined.
It found only "substantial authority" for six of the components.
Because the substantial authority standard is an objective standard, the taxpayer's belief that there is substantial authority for the tax treatment of an item is not relevant in determining whether there is substantial authority for that treatment.
There may be substantial authority for the tax treatment of an item despite the absence of certain types of authority.
All authorities relevant to the tax treatment of an item, including the authorities contrary to the treatment, are taken into account in determining whether substantial authority exists.
There may be substantial authority for more than one position with respect to the same item.
The rules for determining when substantial authority exists are set forth in § 1.6662-4 d).
There is substantial authority for the tax treatment of an item only if the weight of the authorities supporting the treatment is substantial in relation to the weight of authorities supporting contrary treatment.
Mr. Annan, for his part, has not wanted to become involved without wielding substantial authority.
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CEO of Professional Science Editing for Scientists @ prosciediting.com