Correct interpretation of "safe harbor" rule for not paying estimated taxes

I would like someone to confirm that I am interpreting this rule correctly.

 

One of the caveats the IRS lays out for avoiding the underpayment penalty is meeting 100 / 110% of the prior years tax liability.

 

A logical consequence of this would be that somebody having a tax liability of $0 one year and 100 million the next year would not be subject to an underpayment penalty if they chose not to pay any estimated taxes on the 100 million. 

 

Is this correct? Am I missing something?