Pre-Filing Agreement Program Statistics - Calendar Year 2009
The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2009.
|
Issue |
Received |
Accepted |
Closed |
|
Worthless Stock |
4 |
4 |
|
|
IRC 41, Research Credit |
3 |
3 |
2 |
|
IRC 199, Domestic Production |
|
1 |
|
|
Cost Segregation Study |
1 |
1 |
2 |
|
Gain/Loss on Sale/Exchange of Property/Stock |
2 |
1 |
1 |
|
Deductibility of Settlement /Fine Payments |
4 |
4 |
4 |
|
Built in Gain from Acquisition/Sale |
1 |
1 |
1 |
|
Correction of Overaccrued Tax Liability |
|
|
1 |
|
IRC 475 Safe Harbor Election, Mark to Market |
1 |
|
|
|
Deduction for Collectively Bargained Welfare Benefits |
|
|
1 |
|
Creditability of Gaming Tax under IRC 903 |
|
1 |
|
|
Methodology to Compute Discounted Unpaid Losses |
1 |
|
|
|
Deductibility of Repair, Maintenance, and Removal Costs |
1 |
|
|
|
Determination of Placed in Service Date |
1 |
1 |
|
|
Bad Debt Determination |
1 |
|
|
|
Capitalization of Merger/Acquisition Costs |
1 |
2 |
2 |
|
ETI Exclusion or FSC Treatment on Sales |
1 |
|
|
|
Deductibility of Payments to Retire Debt |
1 |
1 |
1 |
|
IRC 481 Adjustment from Change in Accounting Method |
1 |
|
|
|
IRC 891 Exemption Availability |
2 |
|
|
|
Whether Transfer of Assets is a Sale |
1 |
1 |
|
|
Whether Taxpayer has a Permanent Establishment |
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 |
|
Screening Process |
48 |
55 |
53 |
62 |
39 |
|
PFA Evaluation Process |
224 |
292 |
340 |
344 |
235 |
|
Total Time |
273 |
347 |
393 |
406 |
274 |
The chart below shows the numbers of PFAs received, accepted into the program, and closed with an agreement during calendar year 2009 for each industry.
|
CY 2009 |
Received |
Accepted |
Closed |
|
CTM |
4 |
3 |
2 |
|
F |
12 |
8 |
2 |
|
HMT |
7 |
7 |
7 |
|
NRC |
2 |
1 |
1 |
|
RFPH |
3 |
2 |
3 |
|
Total |
28 |
21 |
15 |
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 |
|
Total |
357 |
233 |
169 |
