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Pre-Filing Agreement Program Statistics - Calendar Year 2005

The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2005.

Issue

Received

Accepted

Closed

Worthless Stock

5

3

4

IRC 41, Research Credit

11

4

4

Basis/FMV of Stock Acquired

1

1

2

Cost Segregation Study

5

5

3

Gain/Loss on of Property or Stock

4

1

1

Disposition of Subsidiary

4

4

2

Acquisition Costs

3

3

1

Donation of Intangible

2

1

 

Engaged in US Trade or Business?

2

1

 

Rehabilitation Credit

3

2

 

Abandonment Loss

2

1

 

Like-kind Exchange

1

1

 

Effectively Connected Income

1

1

 

Capitalization of Property, allocation of price

3

1

 

Adjustments to Incentive Plan

1

 

 

Netting of Assets and Liabilities

1

 

 

Write off of Goodwill

1

 

 

Permanent Establishment

2

 

 

Interest Deduction

1

 

 

Withholding & Reporting FICA, Interest, Dividends

2

 

 

The chart below shows the processing time for PFAs during each calendar year, since the program’s inception.

Average Processing Time (Days)

Pilot

 

CY 2001

 

CY 2002

 

CY 2003

 

CY 2004 

CY 2005

Application Screening Process

38

47

53

59

76

48

PFA Evaluation Process

242

126

183

240

285

224

Total Time to Complete a PFA

281

173

235

299

360

273

The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2005 for each industry.

CY2005  Received  Accepted  Closed
CTM 6 2 0

F

8

6

2

HMT

14 8 7

NRC

13

5

3

RFPH

12  8 7

Total

53 29 19

 

 

 

 

 

The chart below shows the number of PFAs received, accepted in to the program, and closed with an agreement during each calendar year since the program’s inception.

 

Received

Accepted

Closed with Agreement

CY 2000

19

12

7

CY 2001

26

18

5

CY 2002

44

25

12

CY 2003

42

29

18

CY 2004

38

22

27

CY 2005

53

29

19

Total

222

135

88

Page Last Reviewed or Updated: 06-Nov-2014