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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Showing 126 - 131 of 131
Find Help| Number | Decision | Issue | Release Date |
|---|---|---|---|
| 1997-12 | Jackson v. Comm, 108 T.C. 130 (1997) ( T.C. # 23558-94). | Reflects the Service's agreement that a former insurance agent is not required to pay tax under the Self-Employment Contributions Act (SECA) on specified contractual termination payments he received from an insurance company upon the termination of his contract with the insurance company. | 03/03/2000 |
| 1999-02 | Larotonda v. Commissioner, AOD CC-1998-010. | An action on decision stating that the Service will not acquiescence to the Court's conclusion in Larotonda. Recent legislation warrants the withdrawing of this AOD. The statutory provision effectively at issue in Larotonda was modified by the Restructuring and Reform Act of 1998, Pub. L. No. 105-206, 112 Stat. 685 (1998), enacted on July 22, 1998. Section 3436 of the Act amends section 72(t) to provided that the early distribution tax shall not apply to a distribution made on account of a levy | 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 |
| 1997-11 | Trans City Life Insurance Company v. Commissioner. | Reflects the Service's disagreement with the Tax Court's conclusion that the Commissioner abused his discretion in determining that reinsurance agreements entered into by the taxpayer with an unrelated insurer had a significant tax avoidance effect. | 03/03/2000 |
| 1997-05 | Hurt v. USA, 70 F.3d 1261 (4th Cir. 1995). | Reflects the Service's disagreement with the Fourth Circuit's opinion that the Service was not entitled to collect statutory interest on the taxes assessed pursuant to a Tax Court decision based upon a settlement agreement. | 03/03/2000 |
| 1997-01 | Xerox Corporation v. United States, 41 F.3d 647 (Fed. Cir. 1994). | Reflects the Service's disagreement that the U.S.-U.K. Income Tax Treaty allows a United States corporation to treat advance tax paid by a U.K. subsidiary as a creditable tax under I.R.C. § 902(a). | 03/03/2000 |
