under consideration


Also found in: Legal.

under consideration

Being thought about or discussed, as in Your application is under consideration; we'll let you know next week. This idiom was first recorded in 1665.
See also: consideration
References in periodicals archive ?
Unlike prior automatic revenue procedures, the audit protection for prior years is not limited to issues under consideration as of the date of issuance or publication of the revenue procedure, but is based on the date of filing Form 3115.
57) The IRS did not adopt the common request to allow taxpayers to file method change requests any time prior to having an issue under consideration since this provision would have resulted in a large number of disputes regarding when an issue came under consideration.
92-20, the new 90-day window allows taxpayers that have been under continuous examination for 12 months as of the beginning of the year of change to request a change in method of accounting for an issue not under consideration or in suspense during the first 90 days of any taxable year.
under continuous examination additional opportunities to change their methods of accounting voluntarily without significantly increasing the potential for disputes regarding when an issue has come under consideration.
The 120-day window period allows taxpayers to request a method change for issues not under consideration or placed in suspense at the time the request is filed during the 120-day period following the date an examination ends, regardless of whether a subsequent examination has commenced.
Since this interregnum will provide examination agents additional opportunities to raise issues under consideration, the new provision effectively eliminates taxpayers' ability to utilize the 120-day window.
For both of these windows, the taxpayer must attach a separate signed statement certifying that, to the best of the taxpayer's knowledge, the requested method change is not an issue under consideration or an issue placed in suspense by the Examination function.
In addition, taxpayers must provide a separate signed statement that the requested change is not an issue under consideration by Appeals or a federal court.
Taxpayers may not file method changes for issues under consideration or placed in suspense.
97-27 provides examining agents with increased opportunities to place an issue under consideration.
95-19 indicates that an interest capitalization issue is under consideration if the taxpayer has received written notification, including an information document request, identifying a method or submethod as under consideration.