1949 - Internal Revenue Service

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222 REPORT OF COMMISSIONER OF INTERNAL REVENUE OFFICE OF THE CHIEF COUNSEL APPEALS DIVISION-WASHINGTON OFFICE TABLE 120.-Cases appealed from Tax Court decisions to appellate courts, fiscal year 1949 332 Pending beginning of fiscal year Received from field for appeal to circuit courts of appeals 297 Total Closed: By decision on merits Transferred to field-remanded for further hearing Total Pending end of fiscal year TABLE 121.-Number and amounts of cases shown in table 120 for the fiscal year 1949, by class of tax and amounts involved Income Estate Gift Class of tax Total TABLE Class of tax Pending Pending Sub' 1, 1948 Number 288 34 10 Amount in dispute $18.646, 411 4,987, 269 148, 064 Filed, reopened, and received fiscal year 1949 Number 271 16 10 Amount in dispute $21, 863, 275 2, 251, 562 171, 378 Closed and trans- `"'" to field, fiscal year 1949 Number 194 20 6 Amount in dispute $7, 736, 806 4, 377, 929 115, 421 Pending June 30, 1949 Number 365 30 14 Amount in dispute $32, 772, 880 2,860,902 204,021 332 23, 781, 744 297 24, 286, 215 220 12, 230,156 409 35, 837, 803 122.-Circuit and Supreme Court cases pending June 30, 1949 New appeals to n Pending InIP 1, 1948 circuit courts of appeals and reopened Number Amount in dispute Number Amount in dispute Closed during ftscal year 1949 Number Amount in dispute Pending Tune 30, 1949 Number 629 215 5 220 409 Amount in dispute REPORT OF COMMISSIONER OF INTERNAL REVENUE 223 TABLE 124.-Progress of cases in appella e courts on appeals from decisions of The Tax Court of the United States for the fiscal year ended June 30, 1949 Cases In aircult courts In Supromo Court Cases In drcult courts Pending beginning of fiscal Closed during fiscal year year: Favorable to Commis- Appealed by Commis- !loner 144 sioner 81 Favorable to taxpayers- 67 Appealed by aYerS 219 Modified 10 Appealed by both 20 Total 211 Total 320 Pending end of fiscal year: Appealed during fiscal year: Appealed by Commis- By Commissioner 98 'loner 104 By taxpayers 180 Appealed by taxpayers__ 267 By both 7 Appealed by both 12 te YO ,O In Supromo Court Total 283 Total 383 9 TABLE 125.-Disposition of Supreme Court, Circuit Court, and Tax Court cases closed during the fiscal year 1949 Character of closing Number of cases Amount in dispute Deficiency Amount approved Ovmeraly- Deficiency Ovmerr- Percent. Net result age of recovery Decision on merits.-- 215 $11,043,470 $1, 023, 840 85, 983, EH $36,245 $8, 971, 129 57.76 TABLE 126.-Disposition of cases closed by The Tax Court of the United States during the fiscal year 1949 Character of closing Number ei c e Amount in dispute Deficiency paOver-m t Amount approved Deficiency paOyver- t Net result CO .0 Percentage of recovery Decision on merits__ 6 $972, 824 $303,346 $400,535 $1,826 $702,055 55.01 Income Estate Gift Total I gia $16, 372,117 4, 908, 530 148,064 256 17 10 $14, 758, 670 2,, 334 301 171, 378 Pc $6, 460, 636 4,377,929 116, 421 348 30 14 $24, 670,151 2, 860,1:02 204, 021 323 21,424, 711 283 17, 264, 349 214 10, 953,986 392 27, 735, 074 , TABLE 123.-Status of cases pending before The Tax Court of the Uni ed States, June 80, 1949 2 On reserve calendar Tried by the Tax Court of the United States: Awaiting expiration of appeal 11 period 13 Total
224 REPORT OF COMMISSIONER OF INTERNAL REVENUE Closed during the year: Cases (exclusive of lien cases) Cases involving liens Total Pending June 30, 1949 Pending July 1, 1948 Received during fiscal year Total Closed during fiscal year Pending June 30, 1949 Excludes bankruptcy, receivership, insolvency, compromise, and liquor cases. 1 FIELD OFFICES APPEALS DIVISION-FIELD OFFICES TABLE 127.-Number and amounts of cases pending in filed divisions, by class of tax and amounts involved Class of tax Incom and profits__ Estates and gift TABLE Total Pending June 30, 1948 Number 5, 384 477 Amount in dispute $434, 931, 738 96, 762, 825 Filed and reopened, fiscal year 1949 Number 4,191 381 Amount in dispute 8157, 931,004 42,007,162 Closed, fiscal year 1949 Number 4,001 332 Amount in dispute $122,561, 824 29,363,610 Pending June 30, 1949 Number 5, 574 526 Amount in dispute 8470,300,918 109, 406,377 5, 861 531, 694, 563 4, 572 199, 938,166 4,333 1n, 925, 434 6,100 579, 707, 295 128.-Disposition of cases by The Tax Court of the United States during the fiscal year 1949 Character of closing Default Decision on merits Agreed settlement Total _ Number of cases - 413 795 3,125 Amount in dispute Deficiency $1,960,440 30, 868,105 105, 648, 358 payment e $56,592 2, 718,046 10, 675,893 Amount approved Deficiency $1,951,027 14,434,863 51, 544, 713 Overpayment $4,661 125, 680 • Net result $2,002,958 17,003, 717 62,443, 540 Percentage of recovery 99.3 50.6 53.7 4,333 138, 476, 903 13, 448, 531 67,930,603 130,341 81, 450, 215 53.6 CIVIL Divis on TABLE 129.-Cases received and disposed of during the fiscal year 1949 1 Number Pending July 1, 1948: In court (exclusive of lien cases) 1, 425 Not pending in court (exclusive of lien cases) 148 582 Cases in court involving liens 49 Cases not in court involving liens Total Received during the year: Suits by taxpayers Suits involving liens Cases for suit by the United States Lien cases not in court Total Total to be disposed of 664 796 172 362 1, 994 538 1, 099 1, 637 2, 561 Amount $92, 950, 825. 16 31, 657, 014. 95 124, 607, 840. 11 16, 493, 951. 86 108, 113, 888. 25 REPORT OF COMMISSIONER OF INTERNAL REVENUE 225 TABLE 130 -Results obtained in cases closed during the fiscal year 1 949 Number Amount Recovered from Amount of cases claimed taxpayers refunded Suits instituted by taxpayers 411 $11, 889,331.44 $7, 134, 126. 48 Suits and claims by the United States 127 4, 604, 620.42 6941, 833. 66 Total 538 16, 493,951.86 941,833. 66 7,134, 126. 48 1 Excludes bankruptcy, receivership, insolvency, compromise, lien, and liquor cases. TABLE 131.-Results obtained in lien cases closed during the fiscal year 1949 1 Lien cases pending in court Lien cases not pending in court 1 Excludes bankruptcy, receivership, insolvency, compromise, and liquor cases. TABLE 132.-Civil cases pending at the beginning and end of the fiscal year 1949 1 1 Excludes bankruptcy, receivership, insolvency, compromise, and liquor cases. Number of cases Amount collected Total 1,099 1, 392, 253.96 For suit by the United States Pending in district courts Involving liens Pending in circuit courts of appeals Pending in Court of Claims Pending in Supreme Court Pending payment of judgment claims State courts and miscellaneous $252,558.35 1,139,695.61 TABLE 133.-Number of Civil Division cases tried by the Department of Justice and number decided by the courts during the fiscal year 1949 753 346 Pending July 1, 1948 148 1,197 631 47 134 0 47 0 Pending June 30, 1949 195 1,390 690 46 171 2 61 0 Total 2, 204 2, 561 District courts Circuit courts of appeals Court of Claims Supreme Court Courts Cases tried For the Government 88 42 6 2 Cases decided Against Government 82 28 8 0 Partly for and partly against Government 9 0 0 Total Total 141 138 116 10 264 88 47 5 179 69 14 2
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IV CONTENTS Miscellaneous Tax Unit
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VIII CONTENTS CONTENTS Table 65. Wi
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1949 - Internal Revenue Service

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