prior understated inclusion
(3) Prior understated inclusions For purposes of this subsection, the term “prior understated inclusion” means the excess (if any) of— (A) the amount which would have been taken into account by the lessor under subsection (a) for periods before the disposition if subsection (b)(2) had applied to the agreement, over (B) the amount taken into account under subsection (a) by the lessor for periods before the disposition.