Pre-Filing Agreement Program Statistics Calendar Year 2012
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 |
