1949 - Internal Revenue Service

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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-
24 REPORT OF COMMISSIONER OF INTERNAL REVENUE plications acted upon during the year numbered 25,491, with requested tax reduction of $215,706,693. Of this number, 22,116 applications with requests for $180,650,257 in tax reductions were allowed in full, the net amount allowed being $181,945,342. Partial allowance was made in 1,836 cases, with $20,873,101 allowed as compared with $24,097,386 requested. There were 1,539 applications requesting tax reductions aggregating $10,959,050 that were disallowed. At the close of the year, applications on hand numbered 2,958 and involved net tax reductions of $14,990,513. Refunds, abatements, and credits.-The amount involved in income and profits tax overassessments of all types for 1949, including cases settled in the collectors' offices as well as in the Income Tax Unit, was $3,512,818,931 as compared with $2,953,437,943 for the preceding year. The following table shows the amounts of abatement, credit, refund, and interest comprising these totals. Amounts -of overassessment, by method of settlement, and interest allowed on income andtexeess profits tax cases closed during the fiscal years 1948 and 1949 Fiscal year 1948 1949 Overassessments settled by- Abatements: $184,173,365 $207, 576,323 Regular 24, 484, Geo 34,086, 295 Duplicate 512, 044, 238 448,620, 499 Credit' 2,178,587,335 2, 738, 995,082 Refund 2,899, 249,871 3, 429, 778,199 Total 54,188, 072 83,540, 732 Interest 2, 953,437, 943 3,512,818,931 Grand total Excludes individual income tax credits of $1,000 or less resulting from excessive prepayments. Inventory of returns on hand in the field offices.-The total number of open income and excess profits tax returns on hand in the field offices of the Income Tax Unit at the close of the year was 815,912, compared with 968,746 on June 30, 1948 (excluding in each year returns tentatively accepted without investigation). The net decrease between the two dates was 152,834, or 15.8 percent. Returns for 1946 and prior tax years on hand as of June 30, 1949, numbered 379,319, as compared with 458,985 returns for 1945 and prior tax years on hand a year ago; thus the prior year returns constituted 46.5 percent of the total number on hand at the close of the fiscal year 1949, as compared with 47.4 percent for 1948. REPORT OF COMMISSIONER OF INTERNAL REVENUE 25 Number of income and excess profits tax returns on hand in the field offices for investigation and in process of settlemen , by tax years, as of June 80, 1948 and 1949 Tax years Number of income and excess profits tax ieturns on hand as of June 30 Tax years Number of income and excess profits tax returns on hand as ofJune 30 1948 1949 1948 1949 ,C.' """° °34*.£8 5 4 4:-.2VH`r:t 1938 835 692 1939 1,428 921 1940 4,986 3,160 1941 13,225 7,952 1942 21,899 13,429 1943 69, 791 33,112 1944 105, 105 52,337 1946 249,748 86,225 1948 470,880 180,132 1947 38,796 362,296 1948 85 74,203 1949 94 Total 968, 746 815, 912 Total prior year returns 458,985 379,319 Total current year returns_._ 609, 761 436,593 The income and excess profits tax returns on hand in the field offices as of June 30, 1948 and 1949, are classified according to pending status in the table which follows: Number of income and excess profits tax returns on hand in the field offices for investigation and in process of settlement, by pending status as of June 80, 1948 and / 949 Pending status Returns on which agents' reports have not been completed: Awaiting classification In process of verification In review or typing._ Total Returns on which agents' reports have been completed: In 30-day file Awaiting action after protest or preliminary notice default In 90-day file Total Grand total Number of income and excess profits tax returns on hand es of June 30 1948 1949 61,103 703, 072 104, 041 51,108 576, 959 82, 350 858,306 710, 417 18,114 87, 016 5, 310 16, 078 84, 248 5,171 110, 440 105, 495 968,746 815, 912 Included above under "returns on which agents reports have been completed" as of June 30, 1949, are 79,485 income and excess profits tax returns involving adjustments not agreed to by the taxpayers, as compared with 83,340 income and excess profits tax returns in such status at the close of the previous year. Pension trust work.-The Bureau, through the Pension Trust Divi- . sion in Washington and through the respective field offices, passes , upon all matters relative to the qualification of stock bonus, pension,
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1949 - Internal Revenue Service

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