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Pre-Filing Agreement Program Statistics - Calendar Year 2006

The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2006.  (The number of issues does not match the number of applications since some have multiple issues.)

Issue

Received

Accepted

Closed

Worthless Stock

4

3

1

IRC 41, Research Credit

7

6

2

IRC 199, Domestic Production

7

5

1

Cost Segregation Study

3

2

3

Gain/Loss on of Property or Stock

2

2

5

Disposition of Subsidiary

 

2

1

Acquisition Costs

2

1

4

Donation and Valuation of Intangible

2

3

1

Loss on Seized Assets

1

1

 

Dividend Received Deduction

1

 

 

Abandonment Loss

 

 

1

Like-Kind Exchange

 

 

1

Effectively Connected Income

1

1

2

Allocation of price on Buyout/Merger

1

 

 

Deductibility of Termination Fee

2

1

1

Deductibility of Settlement Payments

2

1

 

Mark to Market

1

 

 

Permanent Establishment

 

1

 

Interest Deduction

 

1

1

Withholding & Reporting FICA, Interest, Dividends

1

1

1

Loss on Portfolio Transfer

1

 

 

Adjustment due to Change in Accounting Method

1

 

 

Apportionment of General and Admin Expenses

2

2

1

Repatriation of Earnings

1

1

1

Debt Issues

2

2

1

Land Improvements Costs

1

1

 

Pension Plan Issue

1

 

 

Casualty Losses

1

1

 

Disclosure Issue on Listed Transactions

1

 

 

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

CY 2006

Application Screening Process

38

47

53

59

76

48

55

PFA Evaluation Process

242

126

183

240

285

224

292

Total Time to Complete a PFA

281

173

235

299

360

273

347

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.

CY2006 Received

Accepted

Closed

CTM

12

11

7

F

13

5

3

HMT

7

6

6

NRC

 8

7

3

RFPH

6

8

8

Total

46

37

27

 

 

 

 

 

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

Total

268

172

115

Page Last Reviewed or Updated: 27-Nov-2013