Table of Contents

• REG-100420-03
  • AGENCY:
  • ACTION:
  • SUMMARY:
  • DATES:
  • ADDRESSES:
  • FOR FURTHER INFORMATION CONTACT:
  • SUPPLEMENTARY INFORMATION:
    • Paperwork Reduction Act
    • Background
    • Explanation of Provisions
    • Special Analyses
    • Comments and Public Hearing
  • Proposed Amendments to the Regulations
    • PART 1—INCOME TAXES
  • Drafting Information
• REG-105346-03
  • AGENCY:
  • ACTION:
  • SUMMARY:
  • DATES:
  • ADDRESSES:
  • FOR FURTHER INFORMATION CONTACT:
  • SUPPLEMENTARY INFORMATION:
    • Paperwork Reduction Act
    • Background
    • Explanation of Provisions
    • Proposed Effective Date
    • Special Analyses
    • Comments and Public Hearing
  • Withdrawal of Notice of Proposed Rulemaking
  • Proposed Amendments to the Regulations
    • PART 1—INCOME TAXES
  • Drafting Information
• REG-127740-04
  • AGENCY:
  • ACTION:
  • SUMMARY:
  • DATES:
  • ADDRESSES:
  • FOR FURTHER INFORMATION CONTACT:
  • SUPPLEMENTARY INFORMATION:
    • Background and Explanation of Provisions
    • Effective Dates
    • Effect on other Documents
    • Special Analyses
    • Comments and Public Hearing
  • Proposed Amendments to the Regulations
    • PART 1—INCOME TAXES
  • Drafting Information
• Announcement 2005-42
  • Introduction
  • Background
    • PFA Program
    • PFA Process
    • Program Oversight
  • Pre-Filing Agreement Program Accomplishments
    • Statistical Overview of PFA Program — Calendar Year 2004
    • Description of Applications Received in Calendar Year 2004
    • Reasons Why Applications Received in Calendar Year 2004 Were Not Accepted
    • PFA Program Summary (2004 and Prior Calendar Years)
    • Taxpayer Withdrawals (4)
    • IRS Withdrawal (8)
    • Mutual Withdrawal (1)
    • PFAs Executed (27)
    • PFAs Executed in 2004
    • Deductibility and Fair Market Value of Donated Property (6)
    • Amount of Qualified Research and Experimental Credit (6)
    • Fair Market Value of Stock Exchanged (1)
    • Cost Segregation for Asset Class and Recovery Periods (1)
    • Treatment of License Fee Income (1)
    • Deductibility of Fees to Purchase Tax Exempt Securities (1)
    • Gain or Loss on Sale of Stock (1)
    • Worthless Securities and Bad Debts (6)
    • Fuel Credit (1)
    • Ordinary Versus Capital Loss on Property Sale (1)
    • Writedown of Inventory (1)
    • Deductibility of Fines and Penalties (1)
  • Closing Agreements
  • PFA Program Utilization
  • Processing Statistics
    • Application Screening Process
    • PFA Evaluation Process
    • Program Evaluation
    • Comparative Analysis — Processing Statistics
    • Taxpayer Satisfaction Survey
  • Pre-Filing Agreement Program Summary