1949 - Internal Revenue Service

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