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Pre-Filing Agreement Program Statistics Calendar Year 2010

The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2010. 

Issue

Received

Accepted

Closed

Worthless Stock

5

4

3

IRC 41, Research Credit

3

3

3

IRC 199, Domestic Production

1

 

1

Cost Segregation Study and Depreciation Deduction

1

1

 

Gain/Loss on Sale/Exchange of Property/Stock

1

1

 

Deductibility of Settlement /Fine Payments

3

3

1

Built in Gain from Acquisition/Sale

1

 

1

Whether Instrument Issues by Sub is Debt or Equity

1

 

 

Deduction for Unpaid Loss Reserves

1

 

 

Deduction for Collectively Bargained Welfare Benefits

1

1

 

Creditability of Gaming Tax under IRC 903

 

 

1

Deductibility of Repair, Maintenance, and Removal Costs

2

2

 

Determination of Placed in Service Date

 

 

1

Withholding and Reporting on Interest and Dividends

1

 

1

Application of IRC 7874 in Bankruptcy

1

1

 

IRC 481 Adjustment from Change in Accounting Method

1

 

 

IRC 892 Exemption Availability

 

1

 

Whether Transfer of Assets is a Sale

 

 

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

CY 2010

Screening Process

48

55

53

62

39

57

PFA Evaluation Process

224

292

340

344

235

328

Total Time

273

347

393

406

274

385

The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2010 for each industry.

 CY 2010

Received

Accepted

Closed

CTM

3

2

3

F

5

5

4

HMT

6

4

4

NRC

5

5

1

RFPH

4

2

1

Total

23

18

13

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

CY 2010

23

18

13

Total

380

251

182

 

Page Last Reviewed or Updated: 03-Feb-2014