Pre-Filing Agreement Statistics - Calendar Year 2008
The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2008.
|
Issue |
Received |
Accepted |
Closed |
|
Worthless Stock |
2 |
2 |
2 |
|
IRC 41, Research Credit |
3 |
3 |
2 |
|
IRC 199, Domestic Production |
2 |
|
4 |
|
Cost Segregation Study |
1 |
1 |
|
|
Gain/Loss on Sale/Exchange of Property/Stock |
2 |
|
1 |
|
Amount of Net Operating Loss |
1 |
|
|
|
Earnings and Profits |
2 |
1 |
1 |
|
Qualified Film Production Costs as Capital Expense |
1 |
|
|
|
Deductibility of Settlement /Fine Payments |
5 |
3 |
1 |
|
Deductibility of Parachute Payments |
|
|
1 |
|
Interest Deduction on High Yield Discount Obligation |
1 |
|
|
|
Withholding & Reporting FICA, Interest, Dividends |
1 |
1 |
1 |
|
Discharge of Indebtedness |
1 |
1 |
1 |
|
Relief from Business Profits Tax |
1 |
|
|
|
Determination of US Real Property Holding Company |
1 |
1 |
|
|
Character of Loss |
|
|
1 |
|
Depreciation |
|
|
1 |
|
Built in Gain from Acquisition/Sale |
3 |
4 |
2 |
|
Change in Basis for Reserve Computation (IRC 807(f)) |
1 |
1 |
|
|
Substantiation Required for Tax Deduction |
|
|
1 |
|
Correction of Overaccrued Tax Liability |
1 |
1 |
|
|
IRC 475 Safe Harbor Election |
1 |
|
|
|
Deduction for Collectively Bargained Welfare Benefits |
1 |
1 |
|
|
Creditability of Gaming Tax under IRC 903 |
1 |
|
|
The chart below shows the processing time for PFAs during each calendar year, since the program’s inception.
|
Average Days in Process |
Pilot |
CY 2001 |
CY 2002 |
CY 2003 |
CY 2004 |
CY 2005 |
CY 2006 |
CY 2007 |
CY 2008 |
|
Screening Process |
38 |
47 |
53 |
59 |
76 |
48 |
55 |
53 |
62 |
|
PFA Evaluation Process |
242 |
126 |
183 |
240 |
285 |
224 |
292 |
340 |
344 |
|
Total Time |
281 |
173 |
235 |
299 |
360 |
273 |
347 |
393 |
406 |
The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2007 for each industry.
|
Received | Accepted | Closed | |
|
CTM |
5 | 2 | 5 | |
|
F |
8 | 3 | 4 | |
|
HMT |
8 | 6 | 2 | |
|
NRC |
2 | 1 | 4 | |
|
RFPH |
9 | 8 | 4 | |
|
Total |
32 | 20 | 19 |
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 |
|
Total |
329 |
212 |
154 |
