Haven’t seen that yet after 25 years. It just always seems like lazy naming when this isn’t followed. Maybe I missed something.
If I had to hazard some kind of heuristic with 99% applicability, it'd be to always strive to have code with as few indentations (branches) as possible. If your code is getting too indented, those deep Vs are either a sign that your implementation has a strong mismatch with the underlying problem or you need to break things up into smaller functions.