The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2012. Issue Received Accepted Closed Worthless Stock 3 1 1 IRC 41, Research Credit 2 1 2 Cost Segregation Study & Depreciation/Depletion 1 Gain/Loss on Sale/Exchange of Property/Stock 3 4 2 Deductibility of Settlement /Fine Payments 3 3 2 Built in Gain from Acquisition/Sale 1 Treatment of Identified Mixed Straddle (IMS) transactions 1 1 Application of Hedging Rules to Currency Transactions 1 Eligibility to be Treated as a Corporation 1 Treatment of Payments to Exercise Call Options 1 IRC 45, Fuel Credit 1 IRC 199, Domestic Production Credit 1 Utilization/Amount of NOL 1 1 Determination of Whether Taxpayer is a Domestic Corporation 1 1 Application of IRC 7874 in Bankruptcy, Involuntary Conversion 1 Medical Device Excise Tax 6 Allocation to Income of Contractual Payments 2 Earnings and Profits 1 Tax Consequences of a Merger 1 Identified Mixed Straddle Rules 2 Permanent Establishment 1 Gain/Loss on Transfer of Assets to a Foreign Entity 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 CY 2010 CY 2011 CY 2012 Screening Process 48 55 53 62 39 57 40 50 PFA Evaluation Process 224 292 340 344 235 328 225 342 Total Time 273 347 393 406 274 385 265 392 The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2012 for each industry. CY 2012 Received Accepted Closed CTM 7 2 1 F 5 4 2 HMP 9 1 5 NRC 3 1 1 RFTH 9 4 1 Total 33 12 10 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 CY 2010 23 18 13 CY 2011 39 28 22 CY 2012 33 12 10 Total 452 291 214
