Actions on Decisions (AOD)
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An Action on Decision (AOD) is a formal memorandum prepared by the IRS Office of Chief Counsel that announces the future litigation position the IRS will take with regard to the court decision addressed by the AOD.
The following list presents these documents in reverse chronological order, starting in the calendar year 1997.
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| 26 - 50 of 84 files | Show per page: 25 50 100 200 | « Previous | 1 2 3 4 | Next » |
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Number
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Decision
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Issue
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Released
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| 2002-03 | Ridge and Marjory Harlan v. Comm., 116 T.C. 31 (2001) | Reflects the Service''s acquiescence in the Court''s conclusion that held that in determining the applicability of the 6-year period of limitations provided by section 6501(e)(1)(A), second-tier | 03/05/2002 |
| 2002-02 | Sutherland Lumber-Southwest, Inc. v. Comm. | The Action on Decision reflects the Service''s acquiescence in the Tax Court''s conclusion that the disallowance provisions of section 274(a) were inapplicable because "section 274(e) was intende | 02/08/2002 |
| 2002-01 | Intermet Corporation & Subs. v. Comm., 117 T.C. No. 13. | The Action on Decision reflects the Service''s acquiescence in result only to the Court''s conclusion that deductions for state income tax deficiencies and interest thereon as well as interest on | 02/11/2002 |
| 2001-08 | N.Dakota State Univ v. USA, 84 F. Supp. 1043 (D.N.D. 1999), | The Eighth Circuit held that a payment made to a tenured faculty member under the taxpayer's early retirement program was made in exchange for the relinquishment of the tenured faculty members c | 01/01/2002 |
| 2001-07 | Robert L. Beck v. Comm, T.C. 2001-198( filed 07/30/01). | The Action on Decision reflects the Service's acquiescence in the court's conclusion that it had the authority to review respondents denial of equitable relief under section 66(c) in a deficienc | 01/01/2002 |
| 2001-06 | Therese Hahn v. Commissioner, 110 T. C. No. 140 (1998) | Reflects the Service's acquiescence in the court's conclusion that the 1981 amendment did not expressly repeal the effective date of section 2040(b)(1), since there is no language in the 1981 ame | 10/18/2001 |
| 2001-05 | Mesa Oil, Inc. v. United States. | Reflects the Service's nonacquiescence whether a verbatim recording of a collection due process (CDP) hearing is required under §§ 6320 and 6330 to create a judicially reviewable administrative r | 08/23/2001 |
| 2001-04 | Exxon v. Commissioner, 113 T. C. No. 338 (1999). | Reflects the Service's acquiescence in result only in the court's conclusion, with respect to the net income issue, that the PRT allowances effectively compensated for the nondeductibility of inte | 08/17/2001 |
| 2001-03 | Farmland Industries, Inc. v. Comm., T.C. Memo. 1999-388 T.C. | Reflects the Service's acquiescence in the Court's conclusion that held that each corporation was formed, operated, and sold to facilitate the petitioner's petroleum business. Because a sufficie | 03/27/2001 |
| 2001-02 | Arnold W. Vinick v. USA, 205 F.3d 1 (1st Cir. 2000). | Reflects the Service's nonacquiescence in the First Circuit's reversal of the lower court's decision that Vinick was liable as a responsible person under section 6672 for the unpaid withholding t | 02/27/2001 |
| 2001-01 | Security State Bank v. Comm., 214 F.3d 1254 (10 th Cir. 2000). | This Action on decisions reflects the Service's acquiescence in the Court's conclusion that neither section 1281(a)(1) nor section 1281(a)(2) were applicable to short-term loans made in the ordinar | 01/29/2001 |
| 2000-09 | Weisbart v. United States Dept of Treas. & IRS. | Reflects the Service's acquiescence with the United States Court of Appeals for the Second Circuit's decision that section 7502 treats the claim as filed on the date of mailing (August 17, 1995) | 11/17/2000 |
| 2000-08 | John D. Shea v. Commissioner, 112 T.C. 183 (1999) | The Tax Court held that the burden of proof should be placed on the Commissioner with respect to the section 66(b) issue. Rather than relying on established case law for its determination as to | 11/03/2000 |
| 2000-07 | Kathy A. King v. Commissoner, 115 T.C. No. 8 (Aug 10, 2000). | Reflects the Service's acquiescence in the Court's conclusion that held that the nonpetitionering spouse was entitled to notice and an opportunity to intervene. The Tax Court reasoned that the rat | 09/25/2000 |
| 2000-06 | Diane Fernandez v. Commissioner, 114 T. C. No 21. | Reflects the Service's acquiescence in the court's conclusion holding that when a taxpayer makes a requisite election under sections 6015(b) and/or (c) along with its request under section 6015(f), | 09/25/2000 |
| 2000-05 | Osteopathic Medical v. Commissioner, 113 T.C. No. 26. | This Action on Decision reflects the Service's acquiescence in the court's conclusion that held that the taxpayer was not required to account for inventories or to use an accrual method of account | 04/29/2000 |
| 2000-04 | Smith v. Comm, 198 F.3d 515 (5th Cir. 1999), rev'g, 108 T.C. 412. | The Tax Court upheld the Commissioners determination that the claim against the estate should be limited to the amount actually paid. The Tax Court held that, '[w]here a claim is disputed, conti | 05/09/2000 |
| 2000-03 | Simpson v. United States, 183 F.3d 812 (8th Cir. 1999). | Reflects the Service's nonacquiescence in the Court's conclusion, that under the plain language of TRA 86 section 1433(b)(2)(A), the statutory protection applies to transfers under trusts that wer | 03/04/2000 |
| 2000-02 | Ahadpour v. Comm., T.C. Memo. 1999-9. | This Action on Decision reflects the Service's acquiescence in the Court's conclusion, to the extent, that the Tax Court held that petitioners had only a conditional right to retain the escrow pa | 03/03/2000 |
| 2000-01 | McLeod v. United States, 276 F.Supp. 213 (S.D. Ala. 1967). | Reflects the Service's acquiescence in the court's conclusion holding that the Department of Pensions and Security constructively placed the children in the taxpayer's home for adoption by prese | 03/03/2000 |
| 1999-17 | Duke Energy Natural Gas Corporation v. Comm. | Reflects the Service's nonacquiescence in the court's conclusion holding that natural gas gathering systems are property includible in asset class 13.2 and must be depreciated over a 7-year period. | 03/03/2000 |
| 1999-16 | Conway v. Commissioner, 111 T.C. 350 (1998) | Reflects the Service's acquiescence in the Court's conclusion that held that the transaction was a nontaxable exchange pursuant to section 1035. Consequently, the 10-percent penalty under section | 03/03/2000 |
| 1999-15 | William & Helen Woodral v. Commissioner, 112 T.C.19 (1999). | Reflects the Service's acquiescence in the Court's conclusion that it was unnecessary to look to the legislative history because the language of section 6404(g) clearly granted the Tax Court juri | 03/03/2000 |
| 1999-14 | Mutual Assurance, Inc. v. United States, 56 F.3d 1353. | Reflects the Service's nonacquiescence in the court's conclusion that held that a timely filed claim for refund that was allowed in full may be amended after the expiration of the statute of limi | 03/03/2000 |
| 1999-13 | Dubin v. Commissioner, 99 T.C. 325 (1992) . | Reflects the Service's acquiescence in the court's conclusion that held although section 6231(a)(12) expressly provides that a husband and wife who have a joint interest in a partnership shall be | 03/03/2000 |
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