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 initially presents these documents in reverse chronological order, from the present back to calendar year 1997.

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Number Decision Issue Release Date
2021-04 Mayo Clinic v. United States, 997 F.3d 789 (8th Cir. 2021), rev’g, 412 F.Supp.3d 1038 (D. Minn. 2019) Whether the primary function of an educational organization described in section 170(b)(1)(A)(ii) of the Internal Revenue Code must be the presentation of formal instruction. 11/22/2021
2022-01 Quezada v. IRS, 982 F.3d 931 (5th Cir. 2020), rev’g In re Quezada, 124 A.F.T.R.2d 2019-6250 (W.D. Tex. 2019) (aff’g In re Quezada, 122 A.F.T.R.2d 2018-5764 (Bankr. W.D. Tex. 2018)) Did the period of limitations on assessing a taxpayer’s backup withholding liability begin to run when the taxpayer filed a Form 1040 and Forms 1099 omitting payee taxpayer identification numbers? 02/07/2022
2022-02 CSX Corp. v. United States, 18 F.4th 672 (11th Cir. 2021). Whether relocation benefits payments that are made to or for the benefit of employees are excludable from compensation for purposes of RRTA under § 3231(e)(1)(iii) 03/21/2022
2023-01 Trafigura Trading LLC v. United States, 29 F.4th 286 (5th Cir. 2022). Whether a taxpayer is entitled to a tax refund under I.R.C. § 4611(b) on crude oil exports because the tax violates the Export Clause of the United States Constitution, U.S. Const. art. I, § 9, cl. 5. 03/06/2023
2023-02 Complex Media, Inc. v. Commissioner, T.C. Memo. Whether (1) the petitioner was bound by the form of a series of transactions, and (2) the fair market value of a Deferred Payment Right for purposes of section 351(b)(1) equals its issue price. 03/13/2023
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