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Pre-Filing Agreement Program Statistics Calendar Year 2012

The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2012. 

Issue

Received

Accepted

Closed

Worthless Stock

3

1

1

IRC 41, Research Credit

2

1

2

Cost Segregation Study & Depreciation/Depletion

1

 

 

Gain/Loss on Sale/Exchange of Property/Stock

3

4

2

Deductibility of Settlement /Fine Payments

3

3

2

Built in Gain from Acquisition/Sale

1

 

 

Treatment of Identified Mixed Straddle (IMS) transactions

 

1

1

Application of Hedging Rules to Currency Transactions

 

 

1

Eligibility to be Treated as a Corporation

1

 

 

Treatment of Payments to Exercise Call Options

1

 

 

IRC 45, Fuel Credit

1

 

 

IRC 199, Domestic Production Credit

1

 

 

Utilization/Amount of NOL

1

1

 

Determination of Whether Taxpayer is a Domestic Corporation

1

1

 

Application of IRC 7874 in Bankruptcy, Involuntary Conversion

 

 

1

Medical Device Excise Tax

6

 

 

Allocation to Income of Contractual Payments

2

 

 

Earnings and Profits

1

 

 

Tax Consequences of a Merger

1

 

 

Identified Mixed Straddle Rules

2

 

 

Permanent Establishment

1

 

 

Gain/Loss on Transfer of Assets to a Foreign Entity

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

CY 2011

CY 2012

Screening Process

48

55

53

62

39

57

40

50

PFA Evaluation Process

224

292

340

344

235

328

225

342

Total Time

273

347

393

406

274

385

265

392

The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2012 for each industry.

 CY 2012

Received

Accepted

Closed

CTM

7

2

1

F

5

4

2

HMP

9

1

5

NRC

3

1

1

RFTH

9

4

1

Total

33

12

10

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

CY 2011

39

28

22

CY 2012

33

12

10

Total

452

291

214

 

Page Last Reviewed or Updated: 16-Jan-2014