1949 - Internal Revenue Service

30 REPORT OF COMMISSIONER OF INTERNAL REVENUE
Applications for excess profits tax relief (section 722, Internal Revenue Code as
amended)-Cumulative receipts and disposals, fiscal years 1942-1949, inclusive
Item
Number
Excess profits tax reduction
Claimed'
Allowed
Net receipts (excluding transfers and reopened
cases) 53, 651 88, 230, 761, 359
Disposals:
Allowed in whole or in part 7, 791 239, 873,324 891, 650, 443 $37,048,630
Disallowed 10, 659 430, 215,144
Withdrawn 9, 865 697, 094, 076
Eliminated 3,065 5,857, 077
Total disposals_ 31,370 1,371, 839,621 91, 6W, 448 37,0480830
On hand lime 30, 1949:
In agents' offices:
Awaiting investigation 387 79, 205,464
'Under investigation 5, 817 2,122,373, 544
Investigated, awaiting field conference, etc_ 6, 632 1,333, 501, 591
In Excess Profits Tax Council: '
Awaiting decision 3,129 560, 548, 344
Awaiting review 1, 789 373, 355, 494
Unagreed, statutory notice outstanding or to
be issued 1,322 116, 304, 768
Before the Tax Court 437 34,656,033
In process of closing 2, 768 237, 976, WO
Total pending 22,281 4, 857, 921, 738
Amount of tax reduction claimed does not take into account tax adjustments made subsequent to the
BIN of relief applications.
2 uomdsts of applications eliminated from further consideration upon agent's finding that no tax liability
existed.
Based on field office report& Includes cases in transit.
MISCELLANEOUS TAX UNIT
The Miscellaneous Tax Unit is concerned with the administration
of all internal revenue taxes except the income and excess profits
taxes, the taxes applicable to alcoholic beverages, and those relating
to employment. Detailed statements concerning the particular taxes
administered in each of the divisions of the Miscellaneous Tax Unit
are set forth in the paragraphs which follow.
Collections of miscellaneous taxes for the year 1949 were
$6,170,913,938, an increase of $115,231,282 over the collections for
the preceding year.
ESTATE TAX DIVISION.-This division administers the laws applicable
to the estate tax and the gift tax. (On April 1, 1949,. the division
was transferred to the Income Tax Unit and its designation was
changed to Estate and Gift Tax Division.)
Collections of estate tax for the year amounted to $735,780,569, a
decrease of $86,599,552 as compared with collections for the preceding
year.
Collections of gift tax amounted to $60,757,344, which represents
a decrease of $16,207,978, compared with such collections for the
preceding year.
Credits under foreign death duty conventions were allowed in the
sum of $699,151 pursuant to the Tax Convention with the Dominion
of Canada, and $264,186 under the Tax Convention with the United
Kingdom
Returns.-There were 27,815 estate tax returns and 35,599 gift tax
returns received during the year. Estate tax returns are referred to
the internal revenue agents in charge for investigation and deter-
REPORT OF COMMISSIONER OF INTERNAL REVENUE 31
ruination of the tax, and later these returns receive a post-audit
review in the Bureau at Washington. Field investigations in connection
with gift tax returns are conducted only in designated cases,
which are likewise subjected to a post-audit review. All other gift
tax returns are audited in the Bureau in Washington without reference
to the field
Number of estate and gift tax returns on hand, received, and audited during the
fiscal years 1948 and 1949
Estate tax
Gift tax
1948 1949 1948 1949
On hand at beginning of year 21,091 24, 528 19, 276 19,307
Received 25,493 27, 815 30,603 35, 599
Total to be disposed of 46, 584 52, 343 49, 879 54, 906
Disposed of 22, 056 26,101 30,572 31,479
On band at end of year 24,528 26,242 19,307 23,427
During the year, 2,486 out of 2,548 gift tax cases requiring post-audit review were disposed of, leaving on
band only 62 cases requiring similar disposition.
As a result of field investigations and Bureau audits, additional
assessments of tax, interest, and penalty amounting to $113,542,843
were made in estate tax cases and $8,263,653 in gift tax cases. Interest
included in these totals amounted to $13,258,240 in estate tax
cases and $1,117,990 in gift tax cases.
Claims.-There were 1,166 claims for refund of estate tax and gift
tax received during the year, as compared with 1,085 claims received
during the preceding year. Refunds of estate and gift taxes, with
interest thereon, were allowed in the total amount of $18,878,218
representing 2,833 cases. Included in this amount were refunds of
$10,083,179 authorized as a result of court decisions in 83 cases.
Estate tax and gift tax claims received and disposed of, fiscal year 1949
Number
Estate tax claims
Gift tax claims
Refund Abatement Refund Abatement
Amount
Amount
Num
ber
Amount
Amount
Claims filed:
On hand Rine 30, 194& $25, 844, 752.42 9 $35, 541.27 195 $1,850, 708.5 6 $26,361.84
Received 14, 232,975.49 594 9,121,237.65 218 654,170.73 142 243, 718.90
Reopened 3, 157,553. 26 0.00 3 9,810.54 0.00
Total to be disposed
of 1,830 43,235, 281.17 603 9,156, 778.92 416 2, 514, 689.85 148 270,080. 74
Allowed 11,440,001.63 8,943,497.85 153 629, 05119 147 270,073. 67
Credited 0.00 198, 257.02 1 21,945.72 0.00
Rejected 4,871,225.34 13,805.25 109 657,740.24 1 7.07
Total disposed of 817 16,311,226.97 602 9,165,560.12 263 1,308,744.15 148 270, 080.74
r A
On hand June 30, 1949_ 1,013 26,924,054.20 1,218. 80 1,205, 998.70 0.00
No claims filed, overtosesements
allowed 1,696 4,352, 424. 5 8,689,617.41 349,140.55 3 5, 778. 80
Interest allowed 1, 949, 557.28 0.00 136,079.81 0.00
-- A
Total allowed, hp
eluding interest._ 2,385 17, 741, 993.13 883 17,831,372. 448 1,136,22A. 27 150 275,852.47