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Pre-Filing Agreement Program Statistics - Calendar Year 2007

The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2007. 

Issue

Received

Accepted

Closed

Worthless Stock

3

3

3

IRC 41, Research Credit

7

3

4

IRC 199, Domestic Production

1

1

1

Cost Segregation Study

1

1

2

Gain/Loss on Sale/Exchange of Property/Stock

3

5

3

Disposition of Subsidiary

1

 

1

Valuation of Property for Rehab Credit

 

 

1

Loss on Seized Assets

 

 

1

Deductibility of Settlement Payments

 

 

1

Deductibility of Parachute Payments

1

1

 

Permanent Establishment

 

 

1

Withholding & Reporting FICA, Interest, Dividends

2

1

 

Apportionment of General and Admin Expenses

 

 

1

Debt Issues

 

 

1

Buyout and IPO Issues

1

1

 

Character of Loss

2

1

 

Depreciation

2

1

 

Built in Gain from Acquisition/Sale

2

1

 

Deduction for Prior Year Expenses

1

 

 

Substantiation Required for Tax Deduction

1

1

 

Income Exclusion for Sales

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

CY 2007

Application Screening Process

38

47

53

59

76

48

55

53

PFA Evaluation Process

242

126

183

240

285

224

292

340

Total Time to Complete a PFA

281

173

235

299

360

273

347

393


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.

 CY2007

Received

Accepted

Closed

CTM

7

7

5

F

6

2

3

HMT

7

5

4

NRC

5

4

4

RFPH

4

2

4

Total

29

20

20


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

Total

297

192

135

Page Last Reviewed or Updated: 03-Feb-2014