Table of Contents

• Announcement 2004-59
  • Introduction
  • Background
    • PFA Program
    • PFA Process
    • Program Oversight
  • Pre-Filing Agreement Program Accomplishments
    • Statistical Overview of PFA Program — Calendar Year 2003
    • Description of Applications Received in Calendar Year 2003
    • Reasons Why Applications Received in Calendar Year 2003 Were Not Accepted
    • Taxpayer Withdrawals (4)
    • IRS Withdrawal (2)
    • Mutual Withdrawal (2)
    • PFAs Executed (18)
    • Fair Market Value of Assets for Purposes of Determining Built-in Gain
    • Donation of Intangibles (3)
    • Amount of Qualified Research Expenditure and Credit (3)
    • Fair Market Value of Assets Exchanged for Stock in a Tax-Free Exchange (2)
    • Deductibility of Fees Incurred in connection with a Reorganization
    • Bad Debt Deduction for Intercompany Advances
    • Abandonment Losses
    • Utilization of Net Operating Loss (2)
    • Gain or Loss on Sale of Stock
    • Start-up Costs and Operating Expenses
    • Worthless Securities and Bad Debts
    • Fair Market Value of Stock Contributed to Pension Plan
  • Closing Agreements
  • PFA Program Utilization
  • Processing Statistics
    • Phase I — Application Screening Process
    • Phase II — PFA Evaluation Process
    • Program Evaluation
    • Comparative Analysis — Processing Statistics
    • Taxpayer Satisfaction Survey
  • Pre-Filing Agreement Program Summary
• Announcement 2004-62