Pre-Filing Agreement Program Statistics - Calendar Year 2005 |
| |
The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2005.
|
Issue
|
Received
|
Accepted
|
Closed
|
|
Worthless Stock
|
5
|
3
|
4
|
|
IRC 41, Research Credit
|
11
|
4
|
4
|
|
Basis/FMV of Stock Acquired
|
1
|
1
|
2
|
|
Cost Segregation Study
|
5
|
5
|
3
|
|
Gain/Loss on of Property or Stock
|
4
|
1
|
1
|
|
Disposition of Subsidiary
|
4
|
4
|
2
|
|
Acquisition Costs
|
3
|
3
|
1
|
|
Donation of Intangible
|
2
|
1
|
|
|
Engaged in US Trade or Business?
|
2
|
1
|
|
|
Rehabilitation Credit
|
3
|
2
|
|
|
Abandonment Loss
|
2
|
1
|
|
|
Like-kind Exchange
|
1
|
1
|
|
|
Effectively Connected Income
|
1
|
1
|
|
|
Capitalization of Property, allocation of price
|
3
|
1
|
|
|
Adjustments to Incentive Plan
|
1
|
|
|
|
Netting of Assets and Liabilities
|
1
|
|
|
|
Write off of Goodwill
|
1
|
|
|
|
Permanent Establishment
|
2
|
|
|
|
Interest Deduction
|
1
|
|
|
|
Withholding & Reporting FICA, Interest, Dividends
|
2
|
|
|
The chart below shows the processing time for PFAs during each calendar year, since the program’s inception.
|
Average Processing Time (Days)
|
Pilot
|
CY 2001
|
CY 2002
|
CY 2003
|
CY 2004
|
CY 2005
|
|
Application Screening Process
|
38
|
47
|
53
|
59
|
76
|
48
|
|
PFA Evaluation Process
|
242
|
126
|
183
|
240
|
285
|
224
|
|
Total Time to Complete a PFA
|
281
|
173
|
235
|
299
|
360
|
273
|
The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2005 for each industry.
| CY2005 |
Received |
Accepted |
Closed |
| CTM |
6 |
2 |
0 |
|
F
|
8 |
6
|
2 |
|
HMT
|
14 |
8 |
7 |
|
NRC
|
13 |
5
|
3 |
|
RFPH
|
12 |
8 |
7 |
|
Total
|
53 |
29 |
19 |
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
|
|
Total
|
222
|
135
|
88
|
|
|
|
Page Last Reviewed or Updated: January 25, 2012