1949 - Internal Revenue Service

220 REPORT OF COMMISSIONER OF INTERNAL REVENUE
TABLE 117.-Analysis of the work of the Technical Staff during the fiscal
1949-Income, profits, estate, and gift tax cases-Continued
PART II-CASES DOCKETED BY THE TAX COURT
(A) PROGRESS OF WORK
Number
of eases
year
Amount stated in statutory notice 1
Deficiency
in tax
penalty
Ovemssessment
Pending at beginning of year 4,991 $316, 521, 893 $40, 178, 287 $33, 751, 427
Received during year (net-transfers, etc., deducted):
Cases considered before petition 1, 203
Cases not considered before petition 3,368
Cases reopened after trial 53
Total receipts 4,624 158,152, 762 13, 358,288 16, 373, 169
Total to be accounted for 9, 615 474, 674, 655 53, 536, 575 50,124, 596
Disposed of during year:
Closed by stipulation-agreed settlement 3,125 95, 301,836 10, 346, 522 8, 296, 525
Closed by dismissal or default 413 1, 787, 237 173, 203 85,141
Tried before the Tax Court on merits 946 30, 837, 272 1, 235, 517 2, 787, 986
Total disposed of 4, 484 127, 926, 345 11, 745, 242 11,169, 652
Pending at end of year
In hands of technical advisors 3, 093 222, 729,170 35, 404, 063 12, 226,159
In hands of division connspl 2, 038 124, 019,140 6,387, 270 26, 728, 785
Total 5, 131 346, 748, 310 41, 791, 3M 38, 954, 944
1 Includes amount of overassessments stated in statutory notice, and, in addition, overassessments in
certain associated cases in the amount of prior findings of the internal raven agent in charge or of the
Staff. For estate tax eases net amounts are used after deducting additional S ate tax credits allowable if
substantiated.
(B) RESULTS OBTAINED IN STIPULATED CASES
Number of oases
Deficiency in tax
Penalty
Overassessment
Net deficiency and penalty
Stipulations
filed
3, 125
$44, 598, 868
6,945,845
6, 084, 038
Percentage
sustained
46.8
67.1
45, 460, 675 46.7
REPORT OF COMMISSIONER OF INTERNAL REVENUE 221
TABLE 118.-Summary: Income, profits, estate, and gift tax appeals docketed,
stipulated, defaulted, and defended on the merits before the Tax Court (formerly
Board of Tax Appeals), fiscal years 1940 to 1949, inclusive
Fiscal year
Number
docketed
per Tax
Court cornpilations
Number
stipulated
per Tax
Court com -
pilations
Number
defaulted
per Bureau
statistics
Defended
on the
merits per
Bureau
statistics
1940 4,240 3,383 267 1,301
1941 4, 366 3, 064 239 1, 522
1942 3,676 2,517 175 1,269
1943 3,380 2,754 163 1,138
1944 3, 178 1,964 180 927
1945 3, 185 1, 787 160 993
1946 2,777 1,787 142 873
1947 3,652 1,913 217 791
1948 4, 402 2,526 458 949
1949 4,537 3,065 413 946
Total 37, 393 24, 760 2, 414 10, 709
NOTE.-Excess of total dispogals, 37,883 docketed cases over filing of 37,393 represents a reduction of 490
cases in previously existing case inventories.
TABLE 119.-Analysis of work on compromise, extension of time, and final closing
agreement cases, fiscal year 1949
Compromise
cases
Extension
of time
cases
Final closing
agreement
eases
On hand July 1, 1948 1, 197 7 27
Received (net) 2, 434 108 183
Total to be disposed of 3, 631 115 210
Accepted, granted, or approved 881 13 135
Rejected 681 98 25
Withdrawn 245
Transferred 135
Total disposed of I, 942 111 160
On hand June 30, 1949 1, 689 4 60