The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2011. Issue Received Accepted Closed Worthless Stock 3 2 3 IRC 41, Research Credit 5 2 2 Cost Segregation Study & Depreciation/Depletion 2 2 1 Gain/Loss on Sale/Exchange of Property/Stock 7 7 5 Deductibility of Settlement /Fine Payments 5 3 5 Built in Gain from Acquisition/Sale 2 1 1 Deduction for Collectively Bargained Welfare Benefits 1 Creditability of Gaming Tax under IRC 903 1 Withholding/Reporting on Interest/Dividends/Income 3 3 2 IRC 1033, Involuntary Conversion 1 1 1 Valuation/Deductibility of Donated Property 2 2 Treatment of Identified Mixed Straddle (IMS) transactions 1 1 Application of hedging rules to currency transactions 1 1 Eligibility to make a Deemed Sale Election 1 1 1 Cancellation of Indebtedness income 1 1 Loss on Intercompany Debt 1 1 Allocation of Gross Receipts 2 Eligibility for IRC 45 credit 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 Screening Process 48 55 53 62 39 57 40 PFA Evaluation Process 224 292 340 344 235 328 225 Total Time 273 347 393 406 274 385 265 The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2011 for each industry. CY 2011 Received Accepted Closed CTM 10 4 1 F 9 7 5 HMT 11 8 8 NRC 2 2 3 RFPH 7 7 5 Total 39 28 22 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 Total 419 279 204
