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Pre-Filing Agreement Program Statistics Calendar Year 2013

The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2013. 

Issue

Received

Accepted

Closed

Worthless Stock

5

3

2

IRC 41, Research Credit

9

10

4

Cost Segregation Study & Depreciation/Depletion

1

1

2

Gain/Loss on Sale/Exchange of Property/Stock

3

2

5

Deductibility of Settlement /Fine Payments

2

2

 

Treatment of Identified Mixed Straddle (IMS) transactions

1

1

1

Application of Hedging Rules to Currency Transactions

 

 

 

Eligibility to be Treated as a Corporation

 

1

1

IRC 45, Fuel Credit

1

1

1

IRC 199, Domestic Production Credit

 

 

 

Utilization/Amount of NOL

1

 

1

Medical Device Excise Tax

4

8

 

Earnings and Profits

 

1

 

Tax Consequences of a Merger/Acquisition/Liquidation

2

 

1

Creditability of Gaming Tax under IRC 903

1

1

1

Offsetting Interest Rate Risk

1

1

1

Deductibility of a Repurchase Premium

1

1

1

Withholding and Reporting Requirements

3

1

1

Whether Taxpayer is a US Real Property Holding Co.

2

1

 

Characterization of Income

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

CY 2013

Screening Process

48

55

53

62

39

57

40

50

67

PFA Evaluation Process

224

292

340

344

235

328

225

342

348

Total Time

273

347

393

406

274

385

265

392

415

 

The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2013 for each industry.

 CY 2013

Received

Accepted

Closed

CTM

7

9

6

F

4

3

5

HMP

13

11

4

NRC

7

4

3

RFTH

6

8

4

IBC

1

 

 

Total

38

35

22

 

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

CY 2013

38

35

22

Total

490

326

236

 

Page Last Reviewed or Updated: 27-Mar-2014