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Pre-Filing Agreement Program Statistics - Calendar Year 2009

The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2009. 

Issue

Received

Accepted

Closed

Worthless Stock

4

4

 

IRC 41, Research Credit

3

3

2

IRC 199, Domestic Production

 

1

 

Cost Segregation Study

1

1

2

Gain/Loss on Sale/Exchange of Property/Stock

2

1

1

Deductibility of Settlement /Fine Payments

4

4

4

Built in Gain from Acquisition/Sale

1

1

1

Correction of Overaccrued Tax Liability

 

 

1

IRC 475 Safe Harbor Election, Mark to Market

1

 

 

Deduction for Collectively Bargained Welfare Benefits

 

 

1

Creditability of Gaming Tax under IRC 903

 

1

 

Methodology to Compute Discounted Unpaid Losses

1

 

 

Deductibility of Repair, Maintenance, and Removal Costs

1

 

 

Determination of Placed in Service Date

1

1

 

Bad Debt Determination

1

 

 

Capitalization of Merger/Acquisition Costs

1

2

2

ETI Exclusion or FSC Treatment on Sales

1

 

 

Deductibility of Payments to Retire Debt

1

1

1

IRC 481 Adjustment from Change in Accounting Method

1

 

 

IRC 891 Exemption Availability

2

 

 

Whether Transfer of Assets is a Sale

1

1

 

Whether Taxpayer has a Permanent Establishment

1

 

 

The chart below shows the processing time for PFAs during each calendar year.

Average Days  in Process

CY 2005

CY 2006

CY 2007

CY 2008

CY 2009

Screening Process

48

55

53

62

39

PFA Evaluation Process

224

292

340

344

235

Total Time

273

347

393

406

274

The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2009 for each industry.

CY 2009

Received

Accepted

Closed

CTM

4

3

2

F

12

8

2

HMT

7

7

7

NRC

2

1

1

RFPH

3

2

3

Total

28

21

15

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

CY 2009

28

21

15

Total

357

233

169

 

Page Last Reviewed or Updated: 27-Oct-2014