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Pre-Filing Agreement Statistics - Calendar Year 2008

The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2008. 

Issue

Received

Accepted

Closed

Worthless Stock

2

2

2

IRC 41, Research Credit

3

3

2

IRC 199, Domestic Production

2

 

4

Cost Segregation Study

1

1

 

Gain/Loss on Sale/Exchange of Property/Stock

2

 

1

Amount of Net Operating Loss

1

 

 

Earnings and Profits

2

1

1

Qualified Film Production Costs as Capital Expense

1

 

 

Deductibility of Settlement /Fine Payments

5

3

1

Deductibility of Parachute Payments

 

 

1

Interest Deduction on High Yield Discount Obligation

1

 

 

Withholding & Reporting FICA, Interest, Dividends

1

1

1

Discharge of Indebtedness

1

1

1

Relief from Business Profits Tax

1

 

 

Determination of US Real Property Holding Company

1

1

 

Character of Loss

 

 

1

Depreciation

 

 

1

Built in Gain from Acquisition/Sale

3

4

2

Change in Basis for Reserve Computation (IRC 807(f))

1

1

 

Substantiation Required for Tax Deduction

 

 

1

Correction of Overaccrued Tax Liability

1

1

 

IRC 475 Safe Harbor Election

1

 

 

Deduction for Collectively Bargained Welfare Benefits

1

1

 

Creditability of Gaming Tax under IRC 903

1

 

 

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

Average Days

  in Process

Pilot

CY 2001

CY 2002

CY 2003

CY 2004

CY 2005

CY 2006

CY 2007

CY 2008

Screening Process

38

47

53

59

76

48

55

53

62

PFA Evaluation Process

242

126

183

240

285

224

292

340

344

Total Time

281

173

235

299

360

273

347

393

406

The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2007 for each industry.

 

 CY2008

 Received  Accepted  Closed

CTM

 5  2  5

F

 8  3  4

HMT

 8  6  2

NRC

 2  1  4

RFPH

 9  8  4

Total 

 32  20  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

CY 2006

46

37

27

CY 2007

29

20

20

CY 2008

32

20

19

Total

329

212

154

 

Page Last Reviewed or Updated: 29-Nov-2013