1949 - Internal Revenue Service

22 REPORT OF COMMISSIONER OF INTERNAL REVENUE
excess profits tax assessments for the fiscal year 1949 as compared
with the fiscal year 1948 follows:
Additional income and excess profits tax assessments made by the Income Tax Unit
during the fiscal years 1949 and 1948, by nature of assessment
Nature of assessment
FISCAL YEAR 1949
Number
of return
Additional tax Interest Penalty Total
Regular 331,123 $1, 069, 288, 679 202, 969, 750 $31, 637, 703 $1, 303, 894,132
Jeopardy I 1, 479 69, 024,677 16, 108, 495 11, 437, 474 96, 570, 646
Duplicate )
969 6,226, 412 1,514,874 317, 577 8,058,950
Total_
333, 571 1, 144, 537, 855 220, 593, 119 43, 392, 754 1, 408, 523, 728
FISCAL YEAR 1948
Regular 344,014 1, 107, 458, 590 178,461, 722 26, 695, 257 1, 312, 615,509
Jeopardy 1 1, 900 63, 202, 939 10, 435, 153 9, 875, 828 83, 513, 920
Duplicate 1
1, 890 7,495, 373 1, 899, 787 99, 361 9, 494, 521
TotaL
347, 804 1,178,156, 902 190,796,602 36, 670, 446 1, 405, 624, 010
• 1 Duplicate paspasments made under the jeopardy provisions are included with e jeopady esaeamenta.
The force of agents decreased from 7,501 at June 30, 1947, to
6,539 at June 30, 1948, but increased during the fiscal year 1949
to 7,011 at June 30, 1949.
Stage at which additional tax was assessed.-The effectiveness of the
settlement authority vested in field officers is evidenced by the high
proportion of cases closed by agreements with taxpayers, without
the issuance of formal deficiency notices which are otherwise required
by law and from which taxpayers may appeal to the Tax Court.
Of the total number of 332,092 income and excess profits tax returns
on which regular additional assessments (including duplicate-regular)
were made, 318,445 additional assessments, or 95.9 percent, were made
by agreement with the taxpayers without the necessity of a statutory
notice, as compared with 95.8 percent in the fiscal year 1948. Of the
total regular additional tax assessed (including duplicate-regular),
aggregating $1,075,513,178, the amount assessed by agreement was
$991,910,896, or 92.2 percent, as compared with 91.9 percent for last
year.
There follows a table showing, by stage at which additional assessment
was made, the number and amount of additional income and
excess profits tax assessments made during the fiscal years 1948 and
1949:
Additional income and excess profits tax assessments made by the Income Tax Unit
during the fiscal years 1949 and 1948 by stage at which assessment was made
Stage at which additional
assessment was
made
FISCAL YEAR 1949
Number
On agreements executed
prior to issuance
of statutory
notice
318,455
Default or agreement
after Issuance of statntnn
rm.-9n
9 22
Returns
Percent
of
total
95.9
2.8
Additional tax
Amount
291, 910,896
44.930, 293
Percent
of
total
92.2 $180, 172, 403 $23, 660, 297
4.2
10, 209, 211
4, 104,22
1, 195, 743, 596
59, 243, 792
J
REPORT OF COMMISSIONER OF INTERNAL REVENUE 23
Additional income and excess profits tax assessments made by the Income Tax Unit
during the fiscal years 1949 and 1948 by stage at which assessment was made-Con.
Stage at which additional
assessment was
made
FISCAL YEAR 1949-00/1.
In appealed cases, after
trial on the merits
and decisions by the
Tax Court or upon
stipulation before the
court of eases settled
by Technical Staff
and/or Chief Counsel
Total
Feogear6lirdieffovisions of
Number
Returns
Percent
of
total
Additional tax
Amount
Percent
of
total
Interest
Penalty
Total
4, 349. 1.3 $38, 671, 989 3. 6 $14,103,010 $4, 190, 605 $56,965,694
332,092 100.0 1, 075, 513,178 100.0 204,484, 624 31, 955, 280 1, 311, 953, 082
1,479 69, 024, 677 16, 108, 495 11, 437,474 96, 570, 646
Grand total 333, 571 1,144, 537, 855 220, 593,119 43, 392, 754 1, 408, 523, 728
FISCAL YEAR 1948
3n agreements executed
prior to issuance
of statutory notice
331, 300
Default or agreement
95.8 1, 024, 754, 563 91.9 160, 390,076 2, 483, 521 1,204,628,159
after issuance of statutory
notice
10, 475 3.0 40, 301, 970 3.6 8, 228, 639 2413, 880
niga "olnedteltse'xis
50, 644, 489
and decisions by the
Tax Court or upon
stipulation before the
court of cases settled
by Technical Staff
and/or Chief Counsel
4,129 1.2' 49, 897, 430 4.5 11, 742, 794 1,197, 217 62, 837,441
Total
345,904
egear621:drovisions of
100.0 1, 114, 953, 963
1, 900
63, 202, 939
100.0 180, 361, 509
10, 435,153
26, 794, 618
9, 875, 828
1, 322, 110, 090
83, 513, 920
Grand total 347, 804 1, 178,156, 900 190, 796, 662 36, 670, 446 1, 405, 624, 010
For a distribution of the additional assessments made during the
fiscal year 1949 by tax years for each stage at which assessment was
made, see pages 122-128.
Tentative LIFO inventory method adjustments.-Applications for
tentative LIFO adjustments received during the fiscal year 1949
numbered 129 with net tax reductions sought in the amount of
$73,968,557. Applications acted upon during the year numbered
126, with requested tax reduction of $73,647,051-allowed $56,792,377.
At the close of the year, applications on hand numbered three and
involved net tax reductions of $321,506.
Tentative carry-back adjustments.-Applications for tentative carryback
adjustments received during the fiscal year 1949 under the provisions
of section 3780, Internal Revenue Code, numbered 26,044,
with net tax reductions sought in the amount of $198,027,721. Ap-