Pre-Filing Agreement Program Statistics - Calendar Year 2009 |
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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: January 24, 2012
