Pre-Filing Agreement Program Statistics - Calendar Year 2007 |
| |
|
The chart below shows the issues received, accepted into the program, and closed with an agreement during calendar year 2007.
|
Issue
|
Received
|
Accepted
|
Closed
|
|
Worthless Stock
|
3
|
3
|
3
|
|
IRC 41, Research Credit
|
7
|
3
|
4
|
|
IRC 199, Domestic Production
|
1
|
1
|
1
|
|
Cost Segregation Study
|
1
|
1
|
2
|
|
Gain/Loss on Sale/Exchange of Property/Stock
|
3
|
5
|
3
|
|
Disposition of Subsidiary
|
1
|
|
1
|
|
Valuation of Property for Rehab Credit
|
|
|
1
|
|
Loss on Seized Assets
|
|
|
1
|
|
Deductibility of Settlement Payments
|
|
|
1
|
|
Deductibility of Parachute Payments
|
1
|
1
|
|
|
Permanent Establishment
|
|
|
1
|
|
Withholding & Reporting FICA, Interest, Dividends
|
2
|
1
|
|
|
Apportionment of General and Admin Expenses
|
|
|
1
|
|
Debt Issues
|
|
|
1
|
|
Buyout and IPO Issues
|
1
|
1
|
|
|
Character of Loss
|
2
|
1
|
|
|
Depreciation
|
2
|
1
|
|
|
Built in Gain from Acquisition/Sale
|
2
|
1
|
|
|
Deduction for Prior Year Expenses
|
1
|
|
|
|
Substantiation Required for Tax Deduction
|
1
|
1
|
|
|
Income Exclusion for Sales
|
1
|
|
|
The chart below shows the processing time for PFAs during each calendar year, since the program’s inception.
|
Average Processing Time (Days)
|
Pilot
|
CY 2001
|
CY 2002
|
CY 2003
|
CY 2004
|
CY 2005
|
CY 2006
|
CY 2007
|
|
Application Screening Process
|
38
|
47
|
53
|
59
|
76
|
48
|
55
|
53
|
|
PFA Evaluation Process
|
242
|
126
|
183
|
240
|
285
|
224
|
292
|
340
|
|
Total Time to Complete a PFA
|
281
|
173
|
235
|
299
|
360
|
273
|
347
|
393
|
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.
|
CY2007
|
Received
|
Accepted
|
Closed
|
|
CTM
|
7
|
7
|
5
|
|
F
|
6
|
2
|
3
|
|
HMT
|
7
|
5
|
4
|
|
NRC
|
5
|
4
|
4
|
|
RFPH
|
4
|
2
|
4
|
|
Total
|
29
|
20
|
20
|
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
|
|
Total
|
297
|
192
|
135
|
|
|
|
Page Last Reviewed or Updated: January 30, 2012
