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Pre-Filing Agreement Program Statistics Calendar Year 2015

The chart below reflects the issues received, accepted into the program, and closed with an agreement during calendar year 2015.  PFAs accepted may have been received in a previous year; those closed were likely accepted in a previous year.

Issue Received Accepted Closed
Worthless Stock/Bad Debt Deduction

3

3

2

IRC 41, Research Credit

4

1

1

Cost Segregation Study & Depreciation/Depletion

1

 

1

Gain/Loss on Sale/Exchange of Property/Stock

 

 

2

Deductibility of Settlement /Fine Payments

            2

4

2

Treatment of Interest of member of Consolidated Group

1

  

 

Deductibility of Charge offs of Partially Worthless Debt

1

 

 

Tax Consequences of a Merger/Acquisition/Liquidation

2

1

1

Withholding and Reporting Requirements

2

2

3

Bankruptcy Issues

1

1

1

The chart below reflects 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

CY 2014

CY 2015

Screening Process

48

55

53

62

39

57

40

50

67

29

48

PFA Evaluation Process

224

292

340

344

235

328

225

342

348

384

296

Total Time

273

347

393

406

274

385

265

392

415

413

344

The chart below reflects the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2015 for each industry.  PFAs accepted may have been received in a previous year; those closed were likely accepted in a previous year.

 CY 2015 Received Accepted Closed
Communications,  Technology, and Media

3

2

3

Financial Services

1

1

2

Heavy Manufacturing and Pharmaceuticals

6

4

2

Natural Resources and Construction

5

2

3

Retailers, Food, Transportation, and Healthcare

2

1

1

International Business Compliance

 

1

1

Global High Wealth

 

1

1

Total

17

12

13

The chart below reflects the number of PFAs received, accepted in to the program, and closed with an agreement during each calendar year since the program’s inception.  PFAs accepted may have been received in a previous year; those closed were likely accepted in a previous year.

  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

CY 2014

23

11

19

CY 2015 17 12 13
Total

530

349

268

 

Page Last Reviewed or Updated: 08-Feb-2016