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
|
|
|
|
Page Last Reviewed or Updated: January 25, 2012
