In our study, the features were analyzed during hepatobiliary phase and margin in this phase may be more clear than CT images, leading to an overassessment
of the tumor margin, which means, for example, one lesion with one focal protruding in CT may be seen as one withmultiple protruding during hepatobiliary phase in d-EOB-DTPA-dynamic enhanced MRI.
(17) The IRS and taxpayer generally execute IRS Forms 870 (Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment
) and 4549 (Income Tax Examination Changes) to resolve agreed-to items in a federal audit.
(26.) See also Form 870-AD Offer to Waive Restrictions on Assessment and Collection of Tax Deficiency and to Accept Overassessment
as an additional example of an agreement that is signed by both the taxpayer and the IRS that determines a taxpayer's tax liability with finality.
6407 provides that the date on which the IRS first authorizes the scheduling of an overassessment
is considered the date on which the refund or credit is allowed, and, pursuant to Regs.
* a deficiency or overassessment
resulting from adjustments made
The Appellate Court of Connecticut concluded that Goodspeed failed to show that refusal to classify its property as open space resulted in an overassessment
, and that the portion of its land containing the airport was ineligible for open space classification.
* Form 870, Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment
This would be particularly true if assessors compensate the underassessment of one household type with the overassessment
of another, which they would have an incentive to do if they are required to comply with the International Association of Assessing Officer (IAAO) standards or other state rules of a similar nature.
If the income approach has been applied, an overassessment
may occur if nonreal estate items are included.
led to the overassessment
of minority populations." Id.
The company said in an explanation accompanying its amended return that it had previously executed a Form 870-AD, Offer to Waive Restrictions on Assessment and Collection of Tax Deficiency and to Accept Overassessment
, reflecting an agreed overassessment
for 1990 of nearly $128 million, not including the $18.9 million that was the subject of the claim.